ATTACHMENT C RFP 4190 Statement of Work

Environmental Monitoring Support Services for the State-Licensed Disposal Area (SDA) and the Western New York Nuclear Service Center

Background/Objectives

The New York State Energy Research and Development Authority (NYSERDA) seeks proposals from firms to perform Environmental Monitoring Support Services for NYSERDA’s West Valley Site Management Program (WVSMP) at the Western New York Nuclear Service Center (Center), located near West Valley, New York, including the State-Licensed Disposal Area (SDA), and the balance of the Center property (referred to as the Retained Premises [RP]). The objective of this request for proposal (RFP) is to select the services of a highly qualified firm experienced in monitoring and handling of radioactive and/or hazardous material to provide NYSERDA with the services, expertise, and materials needed to implement and support the WVSMP environmental monitoring program for the Center. The scope of work includes, but is not limited to, the following activities:

• groundwater and radioactive/hazardous trench leachate monitoring • groundwater and radioactive trench leachate elevation measurements • surface water monitoring • stormwater monitoring • environmental radiation dosimetry monitoring • low-level radioactive waste disposal services • monitoring well maintenance • monitoring equipment maintenance, repairs, and calibration • support services for health and safety, and emergency response • rapid response and minor effort work activities • geographic information system (GIS)/database support and development

On behalf of the people of New York State, NYSERDA holds title to the 3,331-acre Center. The Center is comprised of three portions: the SDA, the RP, and the West Valley Demonstration Project (WVDP) (see Figures 1-1 and 1-2). The area designated as the WVDP is under the exclusive use and control of the U.S. Department of Energy (DOE). The SDA and the RP are managed solely by NYSERDA for the protection of public health, safety, and the environment. For radiation protection purposes, the SDA and the RP are managed under two separate programs to ensure the safety of the general public, workers, and the environment. Figure 1-1. Site Map – Western New York Nuclear Service Center and Boundary of Retained Premises

Source: NYSERDA

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 2

Figure 1-2. Aerial Photograph of the SDA

Source: NYSERDA

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 3

West Valley Demonstration Project - The WVDP is located adjacent to the SDA and within the 3,331- acre Center located primarily in the Town of Ashford in northern Cattaraugus County. The WVDP facility consists of a secured-fenced area of approximately 167 acres. The areas and facilities that became the WVDP were the site of a former nuclear fuel reprocessing plant, which operated from 1966 until 1972. However, in 1972, the reprocessing plant halted reprocessing to make process improvements; and, in 1976, due to new requirements for waste management, seismic, and tornado protection, the site operator, Nuclear Fuel Services, notified NYSERDA that they would turn the facility over to NYSERDA in 1980, at the end of the initial lease period.

In 1980, Congress passed Public Law 96-368 (WVDP Act), authorizing the DOE to take exclusive use and possession of the fuel reprocessing facilities to carry out the activities described in the WVDP Act. DOE is currently conducting activities related to the requirements of the WVDP Act.

SDA General Description - The SDA, which is adjacent to the WVDP, is regulated by the New York State Department of Health under Radioactive Material License C0382 and the New York State Department of Environmental Conservation (DEC) under a 6 NYCRR Part 380 Radiation Control Permit. An eight-foot high chain-link fence, which includes a one-foot barbed-wire outrigger, surrounds the perimeter of the SDA, and provides a visible barrier to prevent inadvertent or unauthorized entry. The SDA occupies approximately 15 acres of the Center, and consists of 14 disposal trenches, three inactive filled lagoons, and a geomembrane covering the trenches and adjacent lagoons. The two sets of disposal trenches (northern trenches [1 through 7] and the southern trenches [8 through 14]) contain approximately 2.4 million cubic feet of packaged radioactive waste that was placed into the trenches between 1963 and 1975. The trenches were dug into the native silty-clay soil and covered with an eight to 10-foot-thick mounded cap of compacted clay with a drainage swale between adjacent trenches. In addition to the disposal trenches, two storage buildings, referred to as the T-1 and the Frac Tank buildings, are also present. These buildings are used for storage of equipment, materials, small quantities of low-level radioactive waste, and other waste streams awaiting analysis for final disposition. The buildings are also utilized for work areas, and storage of maintenance materials and equipment for monitoring and maintenance of the SDA. During 1992 and 1995, NYSERDA installed a soil-bentonite subsurface barrier wall along the western side of Trench 14 to divert groundwater flow away from the south trenches (8 through 14), and covered the trenches with geomembrane covers to prevent water infiltration into the trenches and divert it toward the adjacent waterways. These measures have greatly reduced water accumulation in the waste disposal trenches.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 4

Retained Premises General Description - The RP portion of the Center is characterized by large open fields (currently in a transition state returning to forest) scattered among wooded acres and is regulated by the Nuclear Regulatory Commission. Buttermilk Creek, which runs south to north through the eastern half of the property, is fed by many small streams and gullies throughout the property. The boundary lines of the property are marked by a three-strand barbed wire fence around the perimeter with posted signs suspended from the fence at regular intervals. The terrain in this area is rough in some places with potentially dangerous heights. Also located on the property, just south of the WVDP, are two small reservoirs, and a firing range that is occasionally used by the WVDP Security personnel. Near the eastern border of the Center, on Buttermilk Road, stands the Bulk Storage Warehouse, which was used in the late 1960s and early 1970s to store plutonium nitrate in a nitric acid solution that was recovered from fuel reprocessing activities at the Center. The Bulk Storage Warehouse is currently unoccupied, and does not contain any hazardous or radioactive wastes.

There are two areas of the Center that are known to contain low levels of residual radioactive contamination: the first being the liquid effluent discharge path from the WVDP to Cattaraugus Creek, which travels through Erdman Brook, Franks Creek, Quarry Creek, and Buttermilk Creek before discharging into Cattaraugus Creek; this pathway has historically exhibited low levels of radiological contamination. The second area of the Center with known levels of residual radioactive contamination is an air deposition pathway extending approximately one and a half miles in the northwesterly direction from the WVDP’s former Main Plant Process Building (currently being decontaminated and decommissioned); this area is referred to as the Cesium Prong, which contains low levels of cesium-137. Routine access in these two areas is currently restricted.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 5

Task 1 Project Management and Progress Reporting

1.1 Responsibility

Regardless of subcontracting arrangements, the Contractor shall be responsible for the timely completion of all the tasks in the Statement of Work (SOW) per the schedule included herein. The Contractor shall provide all project management activities necessary for the performance of this SOW, which shall include the following activities:

• coordinate the work of the Contractor's employees, and those of subcontractors and equipment vendors that are undertaking tasks described in this SOW • ensure control over the project budget and adherence to the project schedule • track training requirements through completion to ensure that personnel complete required training including any required refresher training by the specified due date • ensure all NYSERDA-owned monitoring equipment is maintained, repaired, and calibrated as required • provide all project reporting to NYSERDA as specified in this SOW • review all deliverables for quality and accuracy prior to submittal to NYSERDA • communicate with NYSERDA on all conditions that impact the quality of the data within five business days of identification

1.2 Progress Reporting

The Contractor shall submit monthly progress reports to NYSERDA's Program Manager no later than the 15th of the following month. The Progress Reports shall include information on the following subjects in the order indicated, with appropriate explanation and discussion:

a) name of contractor b) title of the project c) agreement number d) purchase order number e) reporting period f) work completed g) planned work for the next reporting period h) identification of problems i) planned or proposed solutions to correct identified problems j) training status of project personnel including training completion and training due dates k) ability to meet schedule, reasons for slippage in schedule l) schedule - percentage completed and whether forecasted deliverables are on track for completion for quarter presented as a bar chart or milestone chart m) status of submittals to DEC n) budget-analysis of actual costs incurred in relation to the budget

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 6

The Contractor shall also provide a task-specific monthly email to each cognizant NYSERDA Project Manager (PM) describing progress or challenges for the submittal currently in process, and estimated submittal dates for deliverables. In addition to the monthly reports described above, the Contractor shall inform NYSERDA within five business days of identification of any off-normal occurrences that could affect the schedule, or impact NYSERDA’s regulatory or permit obligations.

1.2.1 Deliverables

Written Monthly Progress Reports no later than the 15th of each month. Task-specific monthly email updates to each cognizant NYSERDA PM.

1.3 Subcontracted Services

The Contractor shall place and manage subcontracts with analytical laboratories that are Environmental Laboratory Approval Program (ELAP)-certified, and licensed to receive and analyze radioactive media (e.g., water, soils, etc.) samples. Requirements for the contents of the laboratory data report shall be specified in the contract with the approved analytical laboratory, and in the applicable contractor procedure(s) for data validation and verification. Prior to subcontracts being made, the Contractor shall confirm lab qualifications and compliance with NYSERDA’s regulatory requirements, and the minimum detectable concentration (MDC) and laboratory Contract Required Detection Limits (CRDLs) identified in NYSERDA’s controlled plans and procedures, which are provided in Appendix A. For estimating purposes, the use of expedited analysis should be considered when there is a need to do so due to reporting requirements as presented in Appendix B, Performance Schedule.

1.4 Project Kick-off Meeting

The Contractor shall hold a project kick-off meeting within 30 days from the contract execution date. The Contractor shall coordinate with NYSERDA's Program Manager to arrange the meeting at a mutually convenient time and location. The Contractor is encouraged to invite representatives of subcontractors and equipment vendors to attend this meeting. The purpose of this meeting shall be to finalize the strategies for accomplishing the objectives of this work, and provide/review relevant materials (e.g., progress reports, training requirements, invoicing, and quality and format of reports/deliverables).Within two weeks after the meeting, the Contractor shall submit a brief report summarizing the issues discussed and decisions made, if any, to NYSERDA’s Program Manager, during this meeting.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 7

1.4.1 Deliverables

A brief report summarizing the project kickoff meeting within two weeks after the meeting date.

1.5 Equipment Maintenance

The Contractor shall use, maintain, and calibrate NYSERDA's equipment (e.g., bladder pumps, bladder pump compressor/controller, YSI flow-through water quality monitoring system, radiation detection instrument, and water level indicators) to conduct groundwater and trench leachate elevation measurements and groundwater sampling. All other equipment shall be supplied and maintained by the Contractor.

Annually, the Contractor shall provide off-site servicing of the bladder pump air compressor, including changing the engine motor oil. Necessary maintenance and/or calibrations should be completed prior to the first use of the equipment for each calendar year.

Radiation detection instruments shall be calibrated, and preoperational checks performed and documented in accordance with SDA-RPP027, Operation and Maintenance of Portable Radiation Detection Instruments.

1.5.1 Deliverables

Maintenance records within 15 days of completion of maintenance. Calibration certificates within 15 days of completion of calibration. Preoperational check logs semiannually (e.g., radiation detection instrument).

1.6 Training of Project Personnel

Training requirements are determined based on the potential hazards associated with the work area and task. In addition to the training to be provided by the Contractor as described in Appendix C, Safety, Training, and Handling of Chemicals and Waste, all environmental monitoring personnel, both Contractor and subcontractor, routinely working at the Center under this Agreement shall complete, at a minimum:

• WVSMP Site-Specific training (and annual refresher training) • WVDP General Employee Training (to be recertified every two years) • Radiation Worker Training II (and annual refresher training) • Emergency Response Training as applicable to their work (e.g., Emergency Coordinator [EC] Training, logbook training, AED/first aid)

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 8

Depending on the specific task, the Contractor shall be required to complete additional training deemed necessary to safely accomplish the activity (e.g., ladder safety, confined space, etc.).

All training requirements shall be fulfilled, and documentation of the training shall be submitted to the NYSERDA training coordinator prior to the initiation of work. The Contractor must work closely with the cognizant NYSERDA PM and training coordinator to ensure that training requirements are clearly identified and completed.

1.6.1 Deliverables

Attendance sheets or certifications documenting completion of training prior to the initiation of work. Monthly updates listing the following:

• new personnel completing initial training • list of all project personnel with training/certification expiration dates • list of all project personnel that are no longer employed by the Contractor or subcontractor

1.7 Project Deliverables

Electronic datafiles shall be provided in a file format compatible with NYSIMS database import routines. Electronic data deliverables must be tested with the NYSIMS system before delivery to NYSERDA.

Electronic datafiles shall be provided in a file format compatible with the EQuIS database software application. Electronic data deliverables (EDDs) must be tested with the EQuIS software before delivery to NYSERDA.

The Contractor shall serve as the “data provider” for NYSERDA and shall be responsible for the submission of data to the DEC’s EQuIS Environmental Data Submission System. The Contractor shall provide NYSERDA with documentation of the successful submission and acceptance of EDDs to DEC. The Contractor shall update the EDD format as required by updates or version changes made to the EQuIS system. NYSERDA shall review and approve all submittals prior to transmittal to DEC.

A draft version of each deliverable data report shall be submitted to NYSERDA's cognizant PM for each task no later than 15 calendar days after receipt of the data from the laboratory. NYSERDA will comment on one draft version within 10 business days after receipt of such draft. Within 10 business days after receipt of NYSERDA's comments, the Contractor shall prepare a final version of the report reflecting careful consideration of NYSERDA's comments to the satisfaction of NYSERDA, and submit one

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 9

electronic copy (*.PDF) of the final version of each report for NYSERDA’s approval. NYSERDA reserves the right to receive paper copies of reports upon request.

1.8 Quality Assurance and Data Validation

Quality assurance (QA) and data validation shall be performed as described in the ENV010, Verification and Validation of Radioanalytical Data, and ENV011, Verification and Validation of Chemical Analytical Data. At a minimum, the data validation process shall incorporate the following elements to validate and verify environmental monitoring samples:

• The Environmental Monitoring Program shall be conducted in accordance with the guidance found in the current Environmental Protection Agency (EPA) and DEC publications. • Upon renewal or change of contracts with the analytical laboratories, the Contractor shall provide copies of the revised or renewed contractual agreements, qualifications, or certifications for the analytical laboratories used. • Data shall be reported with an associated uncertainty estimate to the 95 percent confidence level. All data, when reported, shall be rounded to the number of significant figures consistent with the confidence limits. • All reported data shall be validated to identify data qualifiers or limitations associated with the data. Data qualifiers to be used in validating the data include:

o U = Analyte considered not detected above the reported MDC or activity. o J = Analyte identified; the associated numerical value is an estimated quantity. o UJ = The analyte was analyzed for but was not detected. This sample quantitation limit is an estimated quantity. o R = Data determined to be unusable. • Validated data shall be supported by a data validation package equivalent to EPA Level 3. Supporting information, equivalent to that required to compile an EPA Level 4 package, must be available from the laboratory upon request for a period of three years from the sampling date. • A backup data file in Microsoft Excel will be maintained for all data generated in performance of this work. The backup data file shall be maintained by the Contractor for the duration of the contract and made available to NYSERDA at the close of the contract as a closeout deliverable, or at any other time upon request by NYSERDA.

1.9 Annual review of Laboratory Service Provider

The Contractor shall conduct and document an annual review of laboratory service provider’s credentials and their testing results. Environmental Chemistry and Radiochemistry Laboratory providers must be ELAP certified.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 10

1.9.1 Deliverables

No later than February 15, a brief report summarizing the annual review of laboratory service provider’s credentials, their testing results, and any corrective actions identified and/or implemented.

1.10 Project Completion Meeting

The Contractor shall conduct a project completion meeting; it shall occur within the time period covering the last 30 days of the contract. In preparation for this meeting, the Contractor shall prepare a summary of the lessons learned from the work performed during the contract period including feedback from field and office personnel. A copy of this summary shall be provided to NYSERDA at the meeting.

The Contractor shall coordinate with NYSERDA's Program Manager to arrange the meeting at a mutually convenient time and place. The Contractor is encouraged to invite representatives of subcontractors and equipment vendors to attend this meeting. The purpose of this meeting shall be to review lessons learned, provide feedback from field and office personnel, and provide/review relevant materials (e.g., lessons learned for each task, suggestions for program improvements, etc.). Within two weeks after the meeting, the Contractor shall submit to NYSERDA’s Program Manager a brief report summarizing the issues discussed during this meeting.

1.10.1 Deliverables

A lessons learned summary. A brief report summarizing the project completion meeting.

1.11 Plans, Procedures, License, and Permits

Appendix A contains the plans, procedures, license, and permits referenced in this SOW to aid in developing a cost estimate.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 11

Task 2 - Groundwater Monitoring

The Groundwater Monitoring Program will be conducted to provide data sufficient to identify radioactive and volatile organic compounds (VOCs) in groundwater and to identify changing conditions that could be indicative of releases from the SDA trenches.

2.1 Sampling Locations

Groundwater samples will be collected from the 21, 1100-series wells located at the SDA as depicted in Figure 2-1 as required by ENV502, Groundwater Monitoring Plan for the State-Licensed Disposal Area (SDA) at West Valley. Samples from the wells, listed in Table 2-1, will be collected by methods detailed in ENV007, Groundwater Sampling, and managed in accordance with ENV008, Field Sample Management.

Table 2-1. 1100-Series Wells

Source: NYSERDA

Well Well 1101A 1105A 1101B 1105B 1101C 1106A 1102A 1106B 1102B 1107A 1103A 1108A 1103B 1109A 1103C 1109B 1104A 1110A 1104B 1111A 1104C

2.2 Sampling Schedule

The Contractor shall collect one complete set of groundwater samples at each sampling location on a semiannual basis, as prescribed in ENV502. The first semiannual event will be completed between April 1 and May 30, and the second semiannual event will be completed between October 1 and November 30 of each year.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 12

Figure 2-1. 1100-Series Wells at the SDA

Source: NYSERDA

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 13

2.3 Equipment

The Contractor shall use NYSERDA's equipment and Contractor-supplied equipment as described in Task 1. Hazardous chemicals shall be accompanied by current Safety Data Sheets (SDS) and shall be stored off-site unless temporary, on-site storage is approved by the NYSERDA PM. All unused hazardous chemicals shall be removed by the Contractor at the completion of each sampling event.

2.4 Analytical Parameters

The samples will be analyzed for radiological and nonradiological parameters as prescribed in ENV502.

2.5 Detection Limits

The Contractor shall use the minimum detection limit goals identified in ENV502 to set the CRDLs for the Groundwater Monitoring Program. Laboratory MDCs shall be determined for all required analytical parameters for each sampling event and will be reported with the sample results.

The analytical laboratory shall ensure that laboratory method MDCs shall be below the CRDLs in all instances. If the laboratory is unable to achieve these detection limits, they shall notify the Contractor, who shall notify NYSERDA within five business days of the analysis.

2.6 Quality Assurance and Data Validation

Groundwater QA and data validation shall be performed as outlined ENV502 and as described in Task 1 - Project Management.

When the Contractor receives the prevalidated data from the laboratory, they will conduct an initial prevalidation review of the data, and will notify NYSERDA within two weeks of receipt of the data of any potential issues such that resampling, if required, can be prepared for and carried out expeditiously.

2.7 Statistical Assessment

The Contractor shall conduct statistical analyses for exceedances and trends as required by ENV502, and described in ENV009, Assessment and Reporting of SDA Data.

The Contractor shall notify the NYSERDA PM immediately by telephone and email if any of the statistical or comparison thresholds in ENV502 have been exceeded. Due to the low detection limits for

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 14

tritium used in this program, if a tritium result exceeds its relevant criteria as established in ENV502, the Contractor will notify NYSERDA immediately (i.e., the contractor will not wait until formal submittal of the associated report to notify NYSERDA of any exceedances). Similarly, if a gross alpha or gross beta result exceeds their relevant criteria, the Contractor will notify NYSERDA immediately (i.e., the contractor will not wait until formal submittal of the associated report to notify NYSERDA of any exceedances) so that the data can be evaluated and determination made whether resampling is required for the exceeding parameter.

2.8 Data Reporting

The Contractor shall provide NYSERDA with a groundwater data report no later than 45 calendar days after the Contractor receives the analytical data from the laboratory. The semiannual groundwater data report shall include:

• A narrative that describes:

o sampling activities, field conditions, and anything unusual, off normal or noteworthy regarding the sampling event o analytical results o statistical analysis results, with emphasis on any results that exceed statistical or trend triggers, or regulatory standards (6 NYCRR Part 703, Surface Water and Ground Water Quality Standards) o data validation and Quality Assurance/Quality Control (QA/QC) issues (including a description of qualified data) o a description of inspections and maintenance activities conducted o any other information required by ENV502 • Electronic data tables of analytical results, including field-measured parameters. • The results of the biennial internal well inspection (only in year of inspection). • QA information needed to support and defend that the sampling, analysis, validation, and assessment process has met the requirements of ENV502 and all field documentation. Provide all required reports as an electronic file (*.PDF) to the NYSERDA PM. • The Contractor shall develop a single EDD that is compatible both with NYSERDA's NYSIMS database as well as the EQuIS environmental data submission system operated by DEC as described in Task 1.

2.9 Subcontracted Services

The Contractor shall place and manage subcontracts with analytical laboratories as described in Task 1.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 15

2.10 Deliverables

A written groundwater data report meeting the requirements in Section 2.8 to be submitted semiannually, no later than 45 calendar days after the Contractor receives the analytical data from the laboratory.

Electronic copies of all laboratory analysis reports to be submitted with, or in advance of, the written groundwater data report.

Copies of groundwater data validation reports upon request by NYSERDA.

A single EDD that is compatible both with NYSERDA's NYSIMS database as well as the EQuIS environmental data submission system operated by DEC as described in Task 1.

Copies of all field notebooks, sampling logs, chain of custody records, shipping, and packaging records to be provided to NYSERDA annually.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 16

Task 3 - Groundwater and Trench Leachate Elevation Measurements

Groundwater and trench leachate elevation measurements will be conducted monthly and quarterly to provide data to assess the effectiveness of SDA infiltration controls, and to monitor hydrologic conditions in the vicinity of the SDA trenches and filled lagoons. The following items are required components of the groundwater and leachate elevation measurement activity.

3.1 Measurement Locations

The Contractor shall conduct groundwater and/or trench leachate elevation measurements at the 21, 1100- series wells; 19 piezometers; nine slit-trench wells; 13 trench sumps; and one well point (WP-91), as required by ENV502, and ENV501, Leachate Monitoring Plan for the State-Licensed Disposal Area (see Figure 3-1 for measurement locations).

3.2 Measurement Schedule

3.2.1 Groundwater

In accordance with ENV502, the Contractor shall collect groundwater elevation measurements monthly and during each calendar quarter as per Table 3-1, whereby “Q” represents a quarterly measurement and “M” represents a monthly measurement.

ENV502 also requires the coordination of groundwater elevation measurements with the WVDP groundwater elevation measurements.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 17

Figure 3-1. Groundwater and Trench Leachate Elevation Measurement Locations

Source: NYSERDA

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 18

Table 3-1. Groundwater Measurement Locations

Source: NYSERDA

Location Frequency Location Frequency Location Frequency 1101A M/Q 1S-91 Q SMW-1 M/Q

1101B M/Q 2S-91 Q SMW-2 M/Q 1101C M/Q 3S-91 M/Q SMW-3 M/Q 1102A Q 4S-91 M/Q SMW-4 M/Q 1102B Q 4D-91 M/Q SMW-5 M/Q

1103A Q 6S-91 M/Q SMW-6 M/Q 1103B Q 6D-91 M/Q SMW-7 M/Q 1103C Q 9S-91 M/Q SMW-8 M/Q 1104A Q 9D-91 M/Q SMW-9 M/Q

1104B Q 10S-91 M/Q 1104C Q 15S-91 M/Q 1105A Q 16D-91 M/Q 1105B Q 17S-91 M/Q 1106A M/Q 18S-91 M/Q 1106B M/Q 21S-91 M/Q 1107A Q 22S-91 M/Q 1108A M/Q 24S-91 M/Q 1109A M/Q B-14 M/Q 1109B M/Q P1-95 M/Q 1110A Q Q 1111A

3.2.2 Leachate

In accordance with ENV501, the Contractor shall collect leachate elevation measurements monthly and during each calendar quarter, as per Table 3-2.

ENV501 also requires the coordination of leachate level measurements with the SDA quarterly groundwater elevation measurements.

The NYSERDA PM will initiate or direct contact between the Contractor and the cognizant WVDP parties to ensure that measurements are coordinated as required by ENV502 and ENV501.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 19

Table 3-2. Leachate Measurement Locations

Source: NYSERDA

Location Frequency

Trench 1 Q Trench 2 Q Trench 3 Q Trench 4 Q Trench 5 Q Trench 8 Q Trench 9 Q Trench 10N Q Trench 10S Q Trench 11 Q Trench 12 Q Trench 13 M/Q Trench 14 M/Q WP-91 M/Q

NYSERDA reserves the right to request nonroutine measurements of groundwater and leachate elevations at any time. The Contractor shall maintain the resources in order to perform nonroutine measurements at NYSERDA's request, within five business days of NYSERDA’s request.

3.3 Equipment

Dedicated conductivity probes are installed in all piezometers, monitoring wells, slit-trench wells, and 10 of the 13 trench sumps. NYSERDA will provide a hand-held readout device to measure the levels at these locations. The water level measurements for the 1100-series groundwater wells shall be obtained using a Contractor-supplied electronic water level indicator. The three trench sumps that do not have dedicated conductivity probes shall be measured using the dedicated sounding devices installed in these sumps, which require no additional equipment.

The Contractor shall supply all other equipment needed to conduct the trench leachate and groundwater elevation measurements including radiation detection instrumentation (e.g., frisker). The Contractor shall maintain all equipment needed to conduct the trench leachate and groundwater elevation measurements.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 20

3.4 Measurement Parameters

In accordance with ENV502 and ENV501, the Contractor shall measure the outage from the reference point on the well or trench sump casing to the top of the groundwater/trench leachate surface. The Contractor shall calculate the groundwater/trench leachate surface elevation in feet above mean sea level (North American Vertical Datum of 1988 [NAVD 88] and North American Datum of 1983 [NAD 83]) using the reference elevation determined for each measurement location. Any data received from the WVDP will need to be converted from Plant Datum (National Geodetic Vertical Datum 1929) to NAVD 88/NAD 83 datum.

3.5 Quality Assurance and Data Validation

Groundwater and trench leachate elevation measurement QA shall be performed as outlined in ENV006, Groundwater Elevation Measurements, and ENV004, Trench Leachate Elevation Monitoring Procedure for the West Valley Site Management Program, and as described in Task 1 - Project Management.

3.6 Statistical and Other Data Assessments

3.6.1 Leachate Elevation Measurements

On the day of leachate elevation measurements, the Contractor shall use the Trench Leachate Elevation Data Field Measurement Worksheet located in ENV004 and the Trench Leachate Assessment Form in ENV501 to determine whether any leachate elevation measurement has exceeded the reporting criteria identified in ENV501. If any leachate elevation measurement exceeds the reporting criteria, the Contractor shall obtain a confirmation measurement and notify the NYSERDA PM immediately (before leaving the site). The Contractor shall deliver results of the initial and confirmation measurements to the NYSERDA PM.

As described in ENV501, the Contractor shall conduct an annual trend analysis to determine whether the leachate elevations (as measured at the 13 trench sumps and Well Point-91) at the SDA are increasing, decreasing, or stable. The leachate elevation statistical assessment is described in ENV009.

3.6.2 Groundwater Elevation Measurements

After each measurement, the Contractor shall prepare a water elevation contour map for the weathered Lavery till and the Kent Recessional sequence using a base map supplied by NYSERDA within five business days of the measurement. The elevation of the leachate in the trenches (as measured in the trench sumps) will be included on the map for the weathered Lavery till.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 21

As described in ENV502, the Contractor shall conduct an annual trend analysis to determine whether the groundwater elevations (as measured at the 21, 1100-series wells; 19 piezometers; and nine slit-trench wells) at the SDA are increasing, decreasing, or stable. The groundwater elevation statistical assessment is described in ENV009.

3.7 Data Reporting

On the day of the groundwater and trench leachate elevation measurements, the Contractor shall provide the NYSERDA PM with a completed copy of the Trench Leachate Elevation Data Field Measurement Worksheet found in ENV004 and the Trench Leachate Assessment Form in ENV501. If a confirmatory measurement is required, the confirmatory measurement will also be provided to the NYSERDA PM.

Monthly and quarterly groundwater and trench leachate elevation measurement reports shall be received by NYSERDA as follows:

• Monthly – within 15 calendar days of the end of the respective month the measurements are collected • Quarterly – within 15 calendar days of the close of each calendar quarter. The monthly and quarterly groundwater and trench leachate elevation measurement reports shall include:

• A brief narrative that describes:

o Field activities; field conditions; and anything unusual, off normal, or noteworthy in regard to the measurement event. o Measurement results, with particular emphasis on any results that exceed any statistical or comparison trigger (as per Section 3.6). o Electronic versions of contour maps showing the groundwater elevations in the weathered Lavery till and Kent Recessional geologic units. o Tables showing groundwater and leachate elevation measurements in the NAD83/NAVD 88 datum. o The Contractor shall develop a single EDD that is compatible both with NYSERDA's NYSIMS database as well as the EQuIS data submission system operated by DEC. o Electronic files must be provided in a file format compatible with built-in, NYSIMS database import routines. Electronic data deliverables must be tested with the NYSIMS system. The annual statistical assessment report shall be provided to NYSERDA by January 15 (assuming the final groundwater and trench leachate elevation measurements are collected in early December). The annual statistical assessment report shall include:

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 22

• A narrative that describes: o The annual statistical assessment of groundwater and trench leachate elevation trends. o Measurement results, with particular emphasis on any results that exceed any statistical trigger (as per Section 3.6). o Report as an electronic file (*.PDF). Electronic datafiles shall be provided in a file format compatible with the EQuIS database software application. Electronic data deliverables must be tested with the EQuIS software before delivery to NYSERDA.

The Contractor shall serve as the "data provider" for NYSERDA and shall be responsible for the submission of data to the DEC's EQuIS Environmental Data Submission System. The Contractor shall provide NYSERDA with documentation of the successful submission and acceptance of EDDs to DEC. The Contractor shall update the EDD format as required by updates or version changes made to the EQuIS system.

3.8 Deliverables

A written groundwater and trench leachate elevation measurement report meeting the requirements in Section 3.7 to be submitted monthly, no later than15 calendar days after the end of the respective month the measurements are collected.

A written groundwater and trench leachate elevation measurement report meeting the requirements in Section 3.7 to be submitted quarterly, no later than 15 calendar days after the close of each calendar quarter.

A written statistical assessment meeting the requirements included in Sections 3.6 and 3.7 to be submitted to NYSERDA annually by January 15 of the following year.

EDD files that are compatible with both NYSERDA’s NYSIMS database and the EQuIS submission system operated by DEC. (i.e., EDDs must be tested with the NYSIMS system and with the EQuIS software before delivery to NYSERDA).

Copies of all field sheets and field notebooks to be provided to NYSERDA annually.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 23

Task 4 - Surface Water Sampling

The Surface Water Monitoring Program will be conducted to provide data sufficient to identify radioactive constituents in surface water, and changing conditions that could be indicative of releases from the SDA or other nearby facilities. The Surface Water Monitoring Program shall be conducted in accordance with the guidance found in current Multi-Agency Radiological Laboratory Analytical Protocols Manual (MARLAP), and applicable EPA and DEC guidance documents and/or analytical and sampling methods as well as applicable WVSMP plans and procedures.

4.1 Sampling Locations

Surface water sampling shall be conducted at the six locations identified in ENV504, Surface Water Monitoring Plan for the State-Licensed Disposal Area (SDA), including the four adjacent to the SDA; the background location upstream of any potential influences from the SDA or WVDP, and at the Buttermilk Creek annual sampling location downstream of the location where SDA-influenced groundwater daylights to become part of Buttermilk Creek. Surface water samples shall be handled in accordance with ENV008, Field Sample Management. The surface water sampling locations are designated in Table 4-1 and depicted in Figure 4-1.

Table 4-1. Surface Water Sampling Locations

Source: NYSERDA

Designation Location Frequency

WNDCELD South of the SDA on Franks Creek. Quarterly

WNFRC67 East of the SDA on Franks Creek. Quarterly

WNERB53 North of the SDA on Erdman Brook. Quarterly West of the SDA between the SDA and the NDA on Lagoon WNNDADR Road Creek (i.e., before the confluence with Erdman Quarterly Brook). Approximately two kilometers southeast of the SDA on WFBCBKG Buttermilk Creek, just north of the creek's intersection with Quarterly Fox Valley Road. North/northeast of the SDA on Buttermilk Creek, Annually (in approximately midway between the borders of the Center. conjunction with WFBCANL second quarter sampling round)

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 24

Figure 4-1. Surface Water Monitoring Locations near the SDA

Source: NYSERDA

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 25

4.2 Sampling Schedule

One complete set of surface water samples shall be collected at each sampling location during each calendar quarter. Samples from all five quarterly surface water sampling locations shall be collected on the same day. Samples from the Buttermilk Creek Location (i.e., WBFCANL) shall be taken annually during the second quarter sampling event. Surface water samples shall be collected within the first 10 days of the second month of each quarter.

4.3 Equipment

All equipment needed for surface water sampling shall be supplied and maintained by the Contractor. Hazardous chemicals shall be accompanied by a current SDS and shall be stored offsite unless temporary onsite storage is approved by the NYSERDA PM. All unused hazardous chemicals shall be removed by the Contractor at the completion of each sampling event.

4.4 Analytical Parameters

Quarterly and annual surface water samples shall be analyzed for gross alpha, gross beta, and tritium as identified in ENV504, and ENV013, Surface Water Sampling. In addition, the following analyses may be required on a nonroutine basis; as directed by the NYSERDA PM:

• gamma spectroscopy • isotopic analyses by chemical separation methods If required, NYSERDA will request these analyses as a rapid response or minor effort tasks using the Rapid Response or Minor Effort Work Order Form as described in Task 7.

4.5 Detection Limits

The Contractor shall use the CRDLs identified in ENV504 for the required parameters in the Surface Water Monitoring Program. Laboratory MDCs shall be determined for all required analytical parameters for each sampling event and shall be reported with the sample results.

Laboratory method MDCs shall be below the CRDLs in all instances. If the laboratory is unable to achieve these detection limits they shall notify the Contractor, who shall notify NYSERDA within five business days of the analysis.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 26

4.6 Quality Assurance and Data Validation

Surface Water QA and data validation shall be performed as outlined in ENV504, and as described in Task 1 - Project Management.

4.7 Statistical Assessments

The Contractor will perform quarterly statistical assessments of surface water data. The surface water statistical assessment is described in ENV009.

In addition, on an annual basis, the following statistical analyses will be conducted on data from the entire calendar year:

• an outlier test • a determination of data distribution • a determination of whether the on-site data are significantly different from the background location (The appropriate statistical test is dependent on distribution. Normally distributed data will use linear regression, t-test, or z-test. Nonparametric distributions will use the Mann- Whitney or Mann-Kendall tests or others, as appropriate.) The Contractor shall notify the cognizant NYSERDA PM within three business days, if any of the statistical or comparison thresholds have been exceeded.

4.8 Data Reporting

Surface water data reports shall be received by NYSERDA no later than 15 calendar days after the Contractor receives the analytical data from the laboratory. The quarterly surface water data report shall include:

• A narrative which describes:

o Sampling activities, field conditions, and anything unusual, off normal or noteworthy in regard to the sampling event. o Analytical results. o Results of the statistical analyses and data comparisons, with particular emphasis on any results that exceed any statistical or trend triggers or regulatory standards (6 NYCRR Part 703, Surface Water and Ground Water Quality Standards), or other required data comparisons. o Data validation and QA/QC issues (including a description of qualified data). Tables should also be provided that show the sample result in relation to the mean sample result for that location (i.e., above or below the mean), and the relative value of the sample result compared to the previous data point (i.e., increase or decrease).

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 27

• A laboratory data validation report, consistent with MARLAP guidance, is required for all sample analysis data. • The Contractor shall develop a single EDD as specified in Task 1. • Electronic copies of all laboratory analysis reports shall be submitted to NYSERDA with (or in advance of) the surface water data report. Supporting QA information (including compiled analytical data, field notebooks, sampling logs, and chain of custody records), needed to support and defend that the sampling, analysis, validation, and assessment process has met the requirements of ENV504, and shall be provided to NYSERDA annually.

Provide all required reports as an electronic file (*.PDF) to the NYSERDA PM.

4.9 Deliverables

A written surface water data report meeting the requirements in Section 4.8 to be submitted quarterly, no later than 15 days after the Contractor receives the analytical data from the laboratory.

A written statistical assessment meeting the requirements included in Section 4.7 to be submitted to NYSERDA annually within 15 days of the end of the calendar year (i.e., January 15).

Electronic copies of all laboratory analysis reports to be submitted with, or in advance of, the written surface water data report.

Copies of surface water data validation reports annually and upon request by NYSERDA.

An EDD file that is compatible with both NYSERDA’s NYSIMS database and the EQuIS submission system operated by DEC as specified in Task 1.

Copies of all field notebooks, sampling logs, chain of custody records, shipping and packaging records to be provided to NYSERDA annually.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 28

Task 5 - SDA Stormwater Monitoring

NYSERDA is required to collect samples of stormwater discharges from the SDA in accordance with the SDA State Pollutant Discharge Elimination System (SPDES) Permit. Stormwater discharge points are depicted in Figure 5-1. Stormwater runoff will be monitored to assess whether runoff from the SDA geomembrane cover system contains any chemical or radioactive contaminants as listed in the DEC Stormwater permit. Stormwater sampling and analytical procedures shall be consistent with EPA and DEC Stormwater Sampling guidance in EPA Form 2F and National Pollutant Discharge Elimination System Stormwater Sampling Guidance, EPA 833-B-92-001, 7/92, and applicable WVSMP plans and procedures.

The following tasks are required components of the Stormwater Monitoring Program.

5.1 Sampling Locations

There are currently four stormwater outfalls at the SDA. One outfall, designated as W01, will be monitored to characterize stormwater leaving the SDA. The locations of all stormwater outfalls are depicted in Figure 5-1.

In addition to Outfall W01, one other outfall location (W05) will be sampled annually, to provide updated analytical data to support our SPDES permit.

5.2 Sampling Schedule

Stormwater samples shall be collected as required by the SDA SPDES Permit and ENV505, Sampling and Analysis Plan for Stormwater Discharge Monitoring at the State-Licensed Disposal Area (SDA). All samples collected shall be managed in accordance with ENV008, Field Sample Management. The SDA SPDES Permit requires stormwater samples to be collected semiannually: once between January 1 and June 30, and once between July 1 and December 31. Sampling is desired to be performed during a qualified rain event (per EPA Form 2F requirements), as defined as occurring before April 1 for the first semiannual period, and before October 1 for the second semiannual period. In the event a qualified event does not occur prior to April 1 or October 1, a complete set of samples shall be collected from the next rain event (greater than 0.1 inches).

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 29

Figure 5-1. Stormwater Outfall Locations

Source: NYSERDA

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 30

5.3 Equipment

The Contractor is required to supply and maintain all equipment needed to conduct the Stormwater Monitoring Program. Typical equipment includes, but is not limited to, lab-certified sample containers, coolers, preservatives, pH meter, field notebooks, and applicable plans and procedures. When NYSERDA determines that the new automated sampling system is functional, the Contractor will collect and composite samples from the automated sampler and determine flow rates for the storm using the automated flow meter data.

Hazardous chemicals shall be accompanied by current SDS and shall be stored offsite unless temporary onsite storage is approved by the NYSERDA PM. All unused hazardous chemicals shall be removed by the contractor at the completion of each sampling event.

5.4 Analytical Parameters

Stormwater samples will be analyzed for radiological and nonradiological parameters identified in ENV505, which includes the parameters identified in the SDA SPDES permit.

An ELAP-certified laboratory must be used for the stormwater analyses as specified in Task 1.

5.5 Detection Limits

The Contractor shall use the minimum detection limit goals identified in ENV505 to set the CRDLs for the Stormwater Monitoring Program. Laboratory MDCs shall be determined for all required analytical parameters for each sampling event and will be reported with the sample results.

5.6 Quality Assurance and Data Validation

Stormwater QA and data validation shall be performed as outlined and as described in Task 1.

5.7 Statistical Assessments

Each semiannual period, the Contractor shall conduct a statistical analysis for exceedances and trends. The stormwater statistical assessment is described in ENV009.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 31

The Contractor will notify the NYSERDA PM within three business days, if any of the statistical or comparison thresholds have been exceeded.

The Contractor shall also compare the stormwater data against the permit limits identified in the SPDES Permit for Stormwater Discharges and notify NYSERDA immediately of any exceedances.

5.8 Data Reporting

The SDA SPDES Permit for Stormwater Discharges requires that NYSERDA provide DEC with a Discharge Monitoring Report (DMR) no later than 28 days after the close of each semiannual period. The DMR and data input spreadsheet shall be provided to NYSERDA no later than 15 days after the Contractor receives the analytical data from the laboratory, and the DMR no later than 15 days after the close of the semiannual period. Each semiannual data report that supports the DMR will include the following items:

• A narrative which describes:

o sampling activities, field conditions, and anything unusual, off normal or noteworthy about the sampling event o analytical results o results of the statistical assessments and data comparisons, with emphasis on any results that exceed any statistical or trend triggers or SPDES Permit limits o data validation and QA/QC issues (including a description of qualified data). • All data will be reported as required by the DEC DMR Manual for Completing the DMR Report for the National Pollutant Discharge Elimination System and Application Form NY-2C for Industrial Facilities (unless directed by NYSERDA to use an alternative format). • Tables shall also be provided that show the sample result in relation to the mean sample result for that location (e.g., above or below the mean), and the relative value of the sample result compared to the previous data point (e.g., increase or decrease). • Provide all required reports as an electronic file (*.PDF) to the NYSERDA PM.

5.9 Deliverables

A written stormwater data report meeting the requirements in Section 5.8. The report and data input spreadsheet shall be provided to NYSERDA no later than 15 business days after the Contractor receives the analytical data from the laboratory.

DMR data tables no later than 15 days after the contractors’ receipt of validated data from the lab.

A single EDD that is compatible both with NYSERDA's NYSIMS database as well as the EQuIS data submission system operated by the DEC, as described in Task 1.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 32

Copies of supporting QA information and data for field measurements and records needed to support and defend that the sampling, analysis, validation, and assessment process has met the requirements of the ENV505 and SPDES Permit.

5.10 Subcontracted Services

The Contractor shall place and manage subcontracts with analytical laboratories, that are ELAP-certified as specified in Task 1.

5.11 Contingency for Automated Sampler and Flow Meter

The Contractor shall include contingencies to support the development and conversion over to an automated flowmeter and sampler during this contract period. NYSERDA may decide to use the automated sampler and flowmeter to improve sample collection and flow data once installed.

The Contractor shall assume duplicative stormwater sampling, preparation, and analysis for a period of two years (four separate events) during the automated sampling test period.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 33

Task 6 - Environmental Radiation Dosimetry Monitoring

Environmental radiation dosimetry monitoring will be conducted at and around the SDA to quantify the gamma radiation levels present, and to help identify contributions to the SDA gamma radiation field that can originate from nearby WVDP facilities. Environmental dosimetry monitoring at the SDA is conducted using approved dosimeters at fixed locations on a quarterly cycle. The environmental radiation monitoring program shall be conducted in accordance applicable WVSMP plans and procedures.

6.1 Monitoring Locations

Current thermoluminescent dosimeter locations are identified in ENV015, Environmental Thermoluminescent Dosimeter Monitoring and are depicted in Figure 6-1.

6.2 Monitoring Schedule

Two dosimeters will be deployed at each monitoring location for a period of three consecutive months (approximately 91 days). Routine deployment of environmental dosimeters will be scheduled on the working day nearest the fifteenth of the month for each deployment quarter (i.e., March 15 for second quarter, June 15 for third quarter, September 15 for fourth quarter, and December 15 for first quarter). The deployment date of dosimeters can be shifted one to four days to accommodate scheduled workdays, weather conditions, or unforeseen events (e.g., postal delays) in accordance with ENV015. All data will be normalized to 91 days.

6.3 Equipment

All equipment needed for environmental radiation dosimetry monitoring shall be supplied and maintained by the Contractor.

6.4 Analytical Parameters

The gamma radiation exposure will be reported in units of milliroentgen per quarter.

6.5 Detection Limits and Precision

The Environmental Radiation Monitoring Program shall at a minimum meet the performance standards in American National Institute (ANSI) N545-1975 Performance, Testing, and Procedural Specifications for Thermoluminescence Dosimetry (Environmental Applications), and NRC Regulatory Guide 4.13 Rev 1,

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 34

Figure 6-1. Environmental Dosimetry Locations at the SDA

Source: NYSERDA

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 35

Performance, Testing and Procedural Specifications for Thermoluminescence Dosimetry: Environmental Applications.

6.6 Quality Assurance and Data Validation

Quality assurance and data validation will be performed as required by ENV506, Environmental Radiation Monitoring Program Plan for the State-Licensed Disposal Area (SDA), and includes the following requirements:

• Vendors selected for providing and analyzing dosimeters shall provide documented proof of meeting at a minimum ANSI N545-1975 Performance, Testing, and Procedural Specifications for Thermoluminescence Dosimetry (Environmental Applications), and NRC Regulatory Guide 4.13 Rev 1, Performance, Testing and Procedural Specifications for Thermoluminescence Dosimetry: Environmental Applications. • Annually perform a QA assessment as described in ENV506. • Upon renewal or change of contracts with the analytical laboratories, provide copies of the revised contractual agreements, qualifications, or certifications for the analytical laboratories used to analyze the dosimeters. • Dosimeters will have a unique identifier indicating the deployment period and location. • Annealing, calibration, readout, and storage will be, at a minimum consistent, with ANSI- N545-1975. • Each group of dosimeters will contain field, storage, and transit controls. • Data will be reported with an associated uncertainty estimate to the 95 percent confidence level. • All reported data will be validated as specified in Task 1. • A backup data file in Excel or Access 2003 (or later versions) will be maintained for all data generated in performance of this task. The backup data file will be maintained by the Contractor for the duration of the contract and made available to NYSERDA at the close of the contract, or at any other time upon request by NYSERDA.

6.7 Statistical Assessments

Each calendar quarter, the Contractor will conduct statistical analyses of dosimetry data to identify exceedances and trends. The dosimetry statistical assessment is described in WVSMP procedure ENV009.

In addition, on an annual basis, the following statistical analyses will be conducted on validated data from the entire calendar year as described in WVSMP procedure ENV009:

• outlier tests • a determination of data distribution • a determination of whether the onsite dosimetry data is significantly different from the background location. (Appropriate statistical test is dependent on distribution. Normally distributed data will use linear regression, the t-test, or z-test. Nonparametric distributions will use the Mann-Whitney, Mann-Kendall tests or others, as appropriate).

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 36

The Contractor shall notify the NYSERDA PM immediately if any of the statistical or comparison thresholds have been exceeded.

6.8 Data Reporting

Quarterly dosimetry data reports shall be provided to NYSERDA. The reports shall include a narrative that describes:

• monitoring activities, field conditions, and anything unusual, off normal, or noteworthy to the monitoring period • analytical results, with particular emphasis on any results that exceed any statistical or trend triggers, or other required data comparisons • data validation and QA/QC issues (including a description of qualified data) • hard-copy tables of analytical results • Tables and graphs that show the sample results in relation to the mean sample result for that location (e.g., above or below the mean), and the relative value of the sample result compared to the previous data point (e.g., increase or decrease). • Electronic datafiles provided in a file format compatible with the built-in, NYSIMS database import routines (*.mdb, *.dbf, etc.) and DEC EQuIS system. Electronic data deliverables must be tested with a copy of the current NYSIMS system prior to submittal. • Supporting QA information and applicable references or procedures needed to support and defend the sampling, analysis, validation, and assessment activities for the environmental radiation monitoring program. • Annually, provide a table report showing the results of the annual statistical evaluation that compares the annual dosimetry data from each SDA location with the background location. Provide all required reports in electronic file (*.exl, *.PDF) to the NYSERDA PM.

6.9 Subcontracted Services

The Contractor will place and manage subcontracts with dosimetry processor(s), that meet, at a minimum, ANSI N545-1975 Performance, Testing, and Procedural Specifications for Thermoluminescence Dosimetry (Environmental Applications), and NRC Regulatory Guide 4.13 Rev 1, Performance, Testing and Procedural Specifications for Thermoluminescence Dosimetry: Environmental Applications. Prior to issuing a subcontract, the Contractor will inform NYSERDA of the laboratory qualifications.

6.10 Deliverables

• Quarterly dosimetry data reports shall be received by NYSERDA no later than 45 calendar days after the close of the monitoring period for which data was collected. • A single EDD that is compatible both with NYSERDA's NYSIMS database as well as the EQuIS data submission system operated by the DEC, as described in Task 1. • Annual statistical evaluation shall be received by January 30 of the year following the year that the data was collected (e.g., 2020 report received no later than January 30, 2021).

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 37

Task 7 - Rapid Response or Minor Effort Work Activities

NYSERDA can request rapid response or minor effort environmental monitoring support services from the Contractor that are not specifically covered elsewhere in this SOW. Requests for such services will be initiated and authorized by NYSERDA.

7.1 Rapid Response or Minor Effort Work Activities

The following types of work activities can include, but are not limited to, the items described below: • sampling and analysis of seeps, soil, groundwater, leachate, biological samples, surface water, stormwater, standing water, air; or other media to support the WVSMP • other environmental investigations or assessments • providing real-time monitoring of VOCs for environmental monitoring tasks when requested by NYSERDA (data to be incorporated into the report for the specific task) • providing expert advice and consultation on environmental monitoring, sampling, analysis, etc. • providing services for disposal of low-level radioactive waste, mixed, and/or hazardous waste • preparing sampling and analysis plans, procedures, workplans, or other written reports or documentation • procuring, maintaining, and calibrating instruments and equipment • laboratory services • statistical analyses, data assessment, mapping, and/or charting • supporting public meetings and meetings with regulators, NYSERDA management, other contractors, DOE, etc. • providing support for the installation, maintenance, monitoring, and data logging/reporting of stream or stormwater flow measurement devices • providing support for the installation, maintenance, monitoring, and data logging/reporting of meteorological instrumentation at the SDA

7.2 Specific Requirements of Rapid Response or Minor Effort Tasks

Specific information on sampling locations, activities, schedule, equipment, detection limits, precision, analytical parameters, QA, data validation, data assessments, and reporting will be provided by the NYSERDA PM on the Rapid Response or Minor Effort Work Order Form (Form A).

7.3 Rapid Response or Minor Effort Task Work Orders

NYSERDA will request rapid response or minor effort tasks using the Rapid Response or Minor Effort Work Order Form. The Contractor will be requested to submit a brief work order proposal for each task.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 38

Within the time frame specified on the Rapid Response or Minor Effort Work Order Form, the Contractor shall submit a Work Order Proposal to the cognizant NYSERDA PM. The Contractor’s Work Order Proposal should include the information requested on the work order form including:

• brief description of the approach for completing the task • cost estimate • schedule for completing the work and providing deliverables • qualifications of the individual(s) performing the work The NYSERDA PM will review the Contractor’s proposal, attach the proposal to the work order form, and sign the work order form indicating his/her acceptance of the Contractor’s proposal. The Contractor should be prepared to initiate work upon receipt of a fully executed work order by the NYSERDA PM.

7.4 Deliverables

The Contractor will provide the deliverables approved and specified in the Rapid Response or Minor Effort Work Order Form and proposal.

7.5 Initial Task Funding:

For cost estimating purposes, assume $50,000 for this subtask. Expenditure of funds will be authorized by the WVSMP PM’s signature on each work order. If required, additional funding will be provided via NYSERDA’s contracting cost modification process.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 39

Task 8 – Support Services for Health and Safety and Emergency Response

NYSERDA can request support services for health and safety and/or emergency response activities. Requests for such support will be initiated and authorized by NYSERDA.

8.1 Health and Safety and Emergency Response Activities

The following types of work activities can be authorized under this task: • preparation and implementation of a regulatory compliance audit of the safety and health or emergency response program • providing on-call expertise for NYSERDA’s health and safety and/or emergency response programs • providing emergency health and safety/environmental monitoring or sampling services in the field during an emergency event • providing expert advice and consultation on personnel or environmental monitoring, sampling, analysis, etc. to assist the NYSERDA EC during emergency response activities • planning emergency response actions for identified drill scenarios • recommending and/or providing emergency response training for emergency coordinators and staff that is appropriate to their response roles • planning and facilitation of drills/exercises for the SDA and/or Retained Premises. Except for activities requiring an emergency response, the services listed above will be requested using the Rapid Response or Minor Effort Work Order Form and the activation process described in Section 7.3 of this SOW.

8.2 Specific Requirements of Emergency Response Services

NYSERDA can request emergency response services at the SDA or Center to provide support during emergency actions to assist the EC in making response decisions during an emergency. Such services will be implemented in accordance with the most recent revision of WVSMP emergency response plans and procedures. The contractor will mobilize within two hours upon notification from the NYSERDA EC; and, after notifying the NYSERDA EC immediately upon arrival at the emergency, will report to, and act under, the direction of the Incident Commander.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 40

8.3 Deliverables/Documentation

Submit the following deliverables/documentation for this task:

• Copies of the Daily Work Report with the number of hours and labor rates of personnel responding to the emergency, applicable rental rates for each piece of equipment used, and a list of any materials supplied including quantities, immediately upon termination of the emergency. • Copies of any field logs maintained during the event. • A written data report of the results of any requested analyses, including the results of any real- time monitoring performed, to be submitted no later than 15 calendar days after the Contractor receives the analytical data from the laboratory or completes the monitoring task. • Electronic copies of all laboratory analysis reports to be submitted with, or in advance of, the written report. • Copies of data validation reports upon request by NYSERDA • An EDD file that is compatible with NYSERDA’s NYSIMS database

8.4 Initial Task Funding

For cost estimating, assume $40,000 for this subtask. Expenditure of funds will be authorized by the WVSMP PM’s signature on each Rapid Response or Minor Effort Work Order Form.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 41

Task 9 - GIS/Database Support

Provide NYSERDA with timely programming support to upgrade and maintain the WVSMP environmental monitoring database (NYSIMS) and GIS projects. NYSIMS is used to store, report, and link SDA environmental and radiation safety monitoring data. This task will provide expertise to troubleshoot and upgrade the NYSIMS database and GIS project systems to provide uninterrupted access, and the functionality necessary to meet the WVSMP regulatory and management needs.

In addition, NYSERDA anticipates the transition in the near future from NYSIMS to another environmental monitoring database platform (i.e., Earthsoft) due to the need for a more expansive, versatile, and current database platform. The Contractor will be required to develop and present a transition plan for the change to a new environmental monitoring database platform, and if accepted, have the personnel and expertise necessary to implement the transition.

NYSERDA will request support services using the GIS/Database Support Services Work Order Form (Form B). The Contractor will be requested to submit a brief work order proposal for each task. The work order proposal will contain a specific scope, timeframe, and description of deliverables.

9.1 Potential Work Activities for GIS/Database Support Services

Potential tasks associated with NYSIMS or GIS support activities include, but are not limited to, the items described below: • providing programming support to modify or troubleshoot the NYSIMS database and links to associated software packages • providing transitional support in the event a more effective or efficient database format is implemented • modifying the NYSIMS data import routines to accommodate new data sources and formats encountered due to laboratory or contractor changes, or inclusion of new data types • adding data links or profile visualizations to GIS maps • adding functionality, updates, or troubleshooting the NYSERDA GIS 3D Modeling program • adding statistical functions • adding storage, query, and reporting functions for new or specific data types • adding alarm set points for data comparison during data importing • troubleshooting or database repair as required to keep pace with software upgrades • purchasing and/or training for software upgrades or add-ons • providing technical support for LiDAR and orthoimagery datasets, and their application within GIS.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 42

NYSERDA will request NYSIMS support services in accordance with the support services work order process described below.

9.2 Work Order Requirements for Initiation of GIS/Database Support Services

NYSERDA will request NYSIMS support services from the Contractor using the GIS/Database Support Services Work Order Form (Form B). Within 15 business days of receiving a work order, the Contractor shall submit a Work Order Proposal to the NYSERDA PM. The Contractor’s Work Order Proposal should include the following information: • a brief description of the Contractor’s approach for completing the task • cost estimates • a schedule • qualifications of the individuals performing the work. The NYSERDA PM will review the Contractor’s proposal, attach the proposal to the GIS/Database Support Services Work Order Form, and sign the work order form indicating his/her acceptance of the Contractor’s proposal. The Contractor should be prepared to initiate work upon receipt of a fully executed Work Order.

9.3 Deliverables

The Contractor shall provide the following: • electronic copies and/or installation of the modifications on NYSERDA’s system • a physical demonstration of the utility of the programming or system modifications • written documentation of programming changes, maintenance requirements, and user instructions • additional, specific deliverables, for each work order will be described in the work order request.

9.4 Initial Task Funding

For cost estimating, assume $100,000 for this subtask. Expenditure of funds will be authorized by the NYSERDA PM’s signature on each work order.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 43

Task 10 – Five-Year Nonroutine Monitoring

A Five-Year Nonroutine Monitoring Program will be conducted to provide data sufficient to characterize radioactive and VOCs in groundwater and leachate at all SDA locations that are not part of the routine activities detailed earlier in this SOW. The Contractor shall use organic vapor meters equipped with photoionization detectors to measure VOCs in the breathing zone of the worker during sampling activities. This Five-Year Nonroutine Monitoring Program shall be conducted in accordance with the guidance found in current MARLAP and applicable EPA and DEC guidance documents, and/or analytical and sampling methods as well as applicable WVSMP plans and procedures. Laboratories must meet ELAP-certification standards for analyses as specified in Task 1.

10.1 Sampling Locations

Groundwater and leachate samples will be collected from 14 leachate monitoring locations and a maximum of 63 groundwater monitoring locations at the SDA as depicted in Figure 10-1. Mitigation activities currently scheduled at the SDA may result in the removal of some groundwater locations. The estimate provided for this task should include costs for 14 leachate locations and 63 groundwater locations, with the understanding that the number of groundwater locations may be reduced.

10.2 Sampling Schedule

The Contractor shall collect one complete set of groundwater and leachate samples from the 14 leachate monitoring locations and maximum 63 groundwater monitoring locations on a five-year basis. This event will be scheduled to coincide with that year’s first semiannual groundwater sampling event (conducted between April 1 and May 30).

10.3 Equipment

All sampling equipment will be supplied and maintained by the Contractor, including personal protective equipment, submersible pumps required for the leachate sampling, and submersible pumps and/or peristaltic pumps for groundwater sampling in locations. The submersible pumps will be removed after sampling and disposed. Photoionization detectors equipped with both 10.6 and 11.7 electronvolt lamps, with the 10.6 electronvolt lamp detector set to monitor 1,4‐Dioxane. Hazardous chemicals (e.g., nitric acid) shall be accompanied by current SDS, and shall be stored off site unless temporary on-site storage is approved by the NYSERDA PM. All unused hazardous chemicals shall be removed by the Contractor at the completion of each sampling event.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 44

10.4 Analytical Parameters

The five-year nonroutine groundwater samples and leachate samples will be analyzed for radiological and nonradiological parameters as listed below: • VOCs • methanol • iodine-129 • carbon-14/tritium • gross alpha/beta, gamma spec, alpha spec, radium-226/8, technetium-99, iron-55, nickel-59/63, promethium‐147, lead-210, strontium-90, isotopic uranium/americium/plutonium • metals/Mercury • semivolatile organic compounds • flashpoint/anions (chloride, fluoride, sulfate)/total dissolved solids • nitrate-nitrite/ammonia/carbon oxygen demand/total carbon/total inorganic carbon/total organic carbon • pesticides • herbicides • reactive cyanide • reactive sulfide

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 45

Figure 10-1. Five-Year Nonroutine Sampling Locations

Source: NYSERDA

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 46

10.5 Detection Limits

The Contractor shall use the minimum detection limit goals identified in ENV502 to set the CRDLs for the Five-Year Nonroutine Monitoring Program. Laboratory MDCs shall be determined for all required analytical parameters for each sampling event and will be reported with the sample results. A sampling and analysis plan will be provided by NYSERDA.

10.6 Quality Assurance and Data Validation

Groundwater and leachate QA with level four data validation and QA/QC review in accordance with applicable portions of the following procedures: • ENV009, Assessment and Reporting of SDA Data • ENV010, Verification and Validation of Radioanalytical Data • ENV011, Verification and Validation of Chemical Analytical Data

When the Contractor receives the prevalidated data from the laboratory, they will conduct an initial prevalidation review of the data, and will notify NYSERDA within two weeks of receipt of the data of any potential issues such that resampling, if required (i.e., result contamination, sediment presence, unusual exceedance of detection limits), can be prepared for and carried out expeditiously.

Due to the low detection limits for tritium used in this program, if a tritium result exceeds its relevant criteria, the Contractor will notify NYSERDA immediately (i.e., the contractor will not wait until formal submittal of the associated report to notify NYSERDA of any exceedances). Similarly, if a gross alpha or gross beta result exceeds their relevant criteria, the Contractor will notify NYSERDA immediately (i.e., the contractor will not wait until formal submittal of the associated report to notify NYSERDA of any exceedances) so that the data can be evaluated and determination made whether resampling is required for the exceeding parameter.

10.7 Data Reporting

The Contractor shall provide NYSERDA with a Five-Year Nonroutine Monitoring Report no later than 45 calendar days after receipt of the groundwater and leachate analytical data from the laboratory. The groundwater and leachate data report shall include:

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 47

• A narrative that describes:

o sampling activities, field conditions, and anything unusual, off normal or noteworthy in regard to the sampling event o groundwater and leachate analytical results o data validation and QA/QC issues (including a description of qualified data) o any other information required by the Nonroutine Groundwater Sampling Procedures Work Instructions and the Leachate Sampling Work Instructions (NYSERDA will provide work instructions prior to scheduling of work). • Electronic data tables of analytical results, including field-measured parameters. • QA information needed to support and defend the sampling, analysis, validation, and assessment process has met the requirements of the Nonroutine Groundwater Sampling Procedures and/or Work Instructions. • Provide all required reports as an electronic file (*.PDF) to the NYSERDA PM. • The Contractor shall develop a single EDD that is compatible with NYSERDA's NYSIMS database.

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 48

10.8 Subcontracted Services

The Contractor shall place and manage subcontracts with analytical laboratories, that are ELAP-certified in accordance with Task 1. Additionally, the laboratory shall have appropriate radioactive materials license to receive and handle radioactive samples.

10.9 Deliverables

A written Five-Year Nonroutine Monitoring Report meeting the requirements in Section 10.7 to be submitted no later than 45 calendar days after the Contractor receives the analytical data from the laboratory. Electronic copies of all laboratory analysis reports submitted with, or in advance of, the written Five-Year Nonroutine Monitoring Report. Copies of groundwater and leachate data validation reports upon request by NYSERDA. An EDD file that is compatible with NYSERDA’s NYSIMS database. Copies of all field notebooks, sampling logs, chain-of-custody records, shipping, and packaging records to be provided to NYSERDA annually.

10.10 Task Estimate

For cost estimating purpose, assume the following: • 14 leachate locations to be sampled • a maximum of 63 groundwater locations to be sampled, with a potential for a reduced number of locations • all packages containing samples will ship as radioactive material • laboratory receiving samples shall be licensed to receive radioactive material • three personnel onsite per sampling day (10 hour/day, four days/week) • sampling three locations per day • personnel protective equipment consisting of:

o disposable coveralls o disposable latex or nitrile gloves o reusable rubber shoe covers • 25 battery-operated disposable two-inch diameter submersible pumps, associated tubing, and fittings • two marine batteries (includes one as backup) • battery charger • two pump controller boxes (includes one as backup) • two peristaltic pumps (includes one as backup), associated tubing and fittings

Attachment C RFP4190, SOW for Environmental Monitoring Support Services for the SDA & the Center 49

FORM A WEST VALLEY SITE MANAGEMENT PROGRAM RAPID RESPONSE OR MINOR EFFORT WORK ORDER FORM

Work Order No.:______Work Order Title: Date Requested:______Required Completion Da te:______

Scope of Work:

Location:

Required Training:

Deliverables:

Work Order Proposal: A work order is valid only for the issuance of orders to the Contractor that fall within the scope of work as it is defined in the contract. Please prepare a Work Order Proposal in response to the work description above. The Work Order Proposal will include: • a brief description of the Contractor's approach to the work description • a cost estimate for performing the work • a schedule • waste management considerations • personnel requirements • tools and equipment required to complete the work Upon receipt of the Contractor's work proposal, NYSERDA will approve the proposal and return a signed copy of this form, with the Contractor's proposal attached, to the Contractor authorizing the work as described in the proposal. Prior to actual work activities beginning, NYSERDA will require that a health and safety plan be submitted and approved by NYSERDA. In emergency situations, work scope and the minimum health and safety requirements will be prescribed by NYSERDA upon issuance of the Work Order Request.

Authorization: Attach this signed form to approved work order, including the information requested above.

______Project Manager Date

Page 1 of 1 FRM090 Form B WEST VALLEY SITE MANAGEMENT PROGRAM GIS/DATABASE SUPPORT SERVICES WORK ORDER FORM

Work Order No.:

Work Order Title: Required Completion Da te: Date Requested:

Scope of Work:

Deliverables (in addition to those described in the Task Order SOW):

GIS/Database Support Services Work Order Proposal

A work order is valid only for the issuance of orders to the Contractor that fall within the scope of work as it is defined in the contract. Please prepare a Work Order Proposal in response to the work description above. The Work Order Proposal will include: • a brief description of the Contractor’s approach for completing the described work • a cost estimate • a schedule • qualifications of the individuals performing the work

Authorization: Attach this signed form to approved work order, including the information requested above.

Project Manager Date

cc: File #______

Page 1 of 1 FRM091

Appendix A – SDA Plans, Procedures, License, and Permits for WVSMP Environmental Monitoring Program

Alpha-Numeric SDA Plan/Procedure Name Designator ENV004 Trench Leachate Elevation Measurement Procedure ENV006 Groundwater Elevation Measurements ENV007 Groundwater Sampling ENV008 Field Sample Management ENV009 Assessment and Reporting of SDA Data ENV010 Verification and Validation of Radioanalytical Data ENV011 Verification and Validation of Chemical Analytical Data ENV013 Surface Water Sampling ENV014 Stormwater Sampling ENV015 Environmental Thermoluminescent Dosimeter Monitoring ENV501 Leachate Monitoring Plan for the State-Licensed Disposal Area Groundwater Monitoring Plan for the State-Licensed Disposal Area (SDA) at West ENV502 Valley ENV504 Surface Water Sampling Plan Sampling and Analysis Plan for Stormwater Discharge Monitoring at the State- ENV505 Licensed Disposal Area (SDA) Environmental TLD Monitoring Program Plan for the State-Licensed Disposal Area ENV506 (SDA) SDA-RPP027 Operation and Maintenance of Portable Radiation Detection Instruments DOH RML C0832 New York State Department of Health Radioactive Materials License DEC Part 380 RCP WNY Nuclear Service Center Radiation Control Permit ID#9-0422-0011/00011 DEC SPDES Permit NYSDEC SPDES Permit for Stormwater Discharges

This page intentionally left blank.

West Valley Site Management Program Page 1 of 4 ENVIRONMENTAL MONITORING PROCEDURES 06/11/2014

TITLE: Trench Leachate Elevation Monitoring Procedure for the West Valley Site Management Program ENV004.06

1.0 PURPOSE

This procedure establishes the process for monitoring, recording and reporting trench leachate elevations at the State-Licensed Disposal Area (SDA), located at the Western New York Nuclear Service Center (WNYNSC). Leachate elevations in the SDA trenches are monitored by the New York State Energy Research and Development Authority (NYSERDA), or its designated contractor, in accordance with the West Valley Site Management’s (WVSMP) plans and procedures.

2.0 HAZARDS, SAFETY CONTROLS AND TRAINING

All personnel performing work activities in and around the SDA must be aware of the hazards associated with these activities, and use the appropriate precautions and controls to avoid exposure, injury or illness. Safety documentation (i.e., Hazard Identification Form, Industrial Work Permit [IWP] and Radiation Work Permit [RWP]) must be prepared for the work in accordance with WVSMP plans and procedures. The Hazard Identification Form identifies the hazards that may be encountered while performing leachate elevation measurement activities at the SDA. The IWP and RWP establish precautions and controls used to protect workers from these identified facility hazards, including health and safety training requirements and other required safety documentation. Information concerning SDA and Retained Premises hazards and safety controls are described in greater detail in the Site-Specific Training, which is required for all individuals working at the SDA. All personnel performing leachate elevation measurement activities must sign the current IWP and RWP forms prior to performing work.

3.0 LEACHATE ELEVATION MEASUREMENT PROCESS

3.1 Methodologies

Trench leachate elevations will be monitored by using a conductivity probe or sounding device.

3.2 Conductivity Probe Measurements

The designated NYSERDA Project Manager, or the NYSERDA-designated contractor, will measure and record leachate elevations using the conductivity probes in the following manner:

3.2.1 Test equipment for measurement: a) Turn the readout meter on and adjust the sensitivity to the "Number Two" setting. b) Test the readout meter by pushing the test button to verify the operation of the light and audible indicator. If the readout meter does not sound, contact the NYSERDA Project Manager to initiate the repair or replacement of the readout meter. c) Document any changes in the functionality of the readout meter on the Field Measurements Worksheet (Attachment A) in the Comments box. ENV004.06 Page 2 of 4

3.2.2 Conduct Field Measurements: a. Record the name of the data collector (i.e., the person performing the measurements), weather conditions, time and date of the measurement on the Field Measurements Worksheet (Attachment A). b. Unfasten the conductivity probe cable from the casing and connect it to the readout meter. c. Slowly lower the cable into the pipe until the readout meter light and audible signal are activated, indicating contact with the leachate. Note the depth measurement observed on the cable at the top of the riser cap (this is the "outage" value). NOTE: To prevent contamination during measurement, do not lower or remove more than three feet of the cable that is suspended into the pipe. d. Repeat the measurement. If the second measurement is the same as the first, record the outage reading to the nearest hundredth of a foot on the Field Measurements Worksheet (Attachment A) in the Leachate Outage column. If the two readings are different, repeat the measurement a minimum of twice more until a consistent reading is obtained. The readings should agree within approximately 5/100 foot. e. Secure the cable to the casing without removing more than three feet of cable from the pipe. f. If a consistent measurement cannot be achieved or if the conductivity probe is inoperable, record this information on the Field Measurement Worksheet (Attachment A) in the Comments box. The NYSERDA-designated contractor will notify the Project Manager after all other measurements have been made. If the NYSERDA Project Manager is performing the measurements, the NYSERDA Project Manager will notify the SDA & Retained Premises Program Manager after all other measurements have been made. g. Turn the readout meter off.

3.3 Sounding Device Measurements

The designated NYSERDA Project Manager or the designated contractor will measure and record leachate elevations in the following manner:

3.3.1 Record the name of the data collector (i.e., the person performing the measurements), weather conditions, time and date of the measurement on the Field Measurements Worksheet (Attachment A). 3.3.2 Obtain a measurement by raising the sounding device above the level of water and letting it drop quickly to produce a splashing sound. 3.3.3 Continue “splashing” the sounding device, raising the cable in decreasing amounts and letting it drop until you are able to estimate the point on the cable that corresponds to where the sounding device contacts the leachate. NOTE: To prevent contamination during measurement, do not remove more than three feet of the cable that is suspended into the pipe. 3.3.4 Record the depth measurement observed on the cable at the top of the riser cap in feet and inches (or hundredths of a foot). 3.3.5 Repeat the measurement. If the two readings are different, repeat the measurement a minimum of twice more until a consistent reading is obtained. The readings should agree within approximately 15/100 of a foot. 3.3.6 Record the outage reading on the Field Measurements Worksheet (Attachment A) in the Leachate ENV004.06 Page 3 of 4

Outage column. 3.3.7 Secure the cable to the casing. 3.3.8 If a consistent measurement cannot be achieved or if the sounding device is inaudible, record this information on the Field Measurements Worksheet (Attachment A) in the Comments box. The NYSERDA-designated contractor will notify the NYSERDA Project Manager after all other measurements have been made. If the NYSERDA Project Manager is performing the measurements, the NYSERDA Project Manager will notify the SDA & Retained Premises Program Manager after all other measurements have been made.

4.0 DATA ASSESSMENT, FOLLOW-UP ACTIONS AND NOTIFICATIONS

4.1 Leachate elevations are measured using one of the techniques described in Section 3.0; the data are recorded on the Field Measurements Worksheet (Attachment A) and in the NYSIMS Database by the NYSERDA Project Manager. 4.2 Leachate elevations are determined by measuring a depth-to-the-top-surface of the leachate, which is converted to an elevation in feet above mean sea level. This conversion is done by subtracting the outage to leachate from the known surveyed elevation of the cap top. 4.3 Leachate elevation data is reviewed by the cognizant NYSERDA Project Manager, or by an independent WVSMP staff member if the cognizant NYSERDA Project Manager performed the measurements, to ensure that there are no transcription or calculation errors. 4.4 Database entries are reviewed by an independent WVSMP staff member to ensure that there are no transcription or calculation errors. 4.5 Data assessment for leachate elevations involves an evaluation of the change in leachate elevation in trenches over time. Needed follow-up activities, if any, will depend on the magnitude of the change (as per WVSMP plans and procedures). These plans and procedures also define the leachate level conditions that will trigger notification to the New York State Department of Environmental Conservation and reporting requirements for routine leachate level measurements. 4.6 In addition to assessing the leachate data for short-term changes, an annual review of long-term leachate level trends will be conducted and the results provided in the SDA Annual Report.

5.0 RECORDS

Completed measurement worksheets, leachate level trend reports, maintenance logs and miscellaneous activities are filed in the WVSMP Central Files by the NYSERDA Project Manager.

6.0 OPERATIONAL CHECKS AND MAINTENANCE OF EQUIPMENT

6.1 Maintenance and repair of leachate elevation measurement equipment will be performed as needed. These activities will be arranged for by the cognizant NYSERDA Project Manager who will coordinate, as necessary, with the WVSMP Safety staff and other WVSMP staff prior to beginning work. ENV004.06 Page 4 of 4

7.0 DEFINITIONS

7.1 Conductivity Readout Meter - A device that receives an electrical signal from a conductivity probe, activating a red light and an audible alarm. 7.2 Conductivity Probe - A device for measuring water levels that produces an electrical signal upon contact with water. It is used in conjunction with a conductivity meter to perform actions in accordance with this procedure. 7.3 Sounding Device - A weight at the end of a cable, used to "splash" in water in order to estimate the distance to the water.

8.0 ATTACHMENTS

Attachment A: Trench Leachate Elevation Data Field Measurements Worksheet (one page).

ATTACHMENT A Trench Leachate Elevation Data Field Measurements Worksheet

This page intentionally left blank. Attachment A TRENCH LEACHATE ELEVATION DATA FIELD MEASUREMENTS WORKSHEET

Data Collector: Date/Time:

Weather Conditions: Comments:

Trench Measurement Survey Pipe Leachate Leachate Comments/ Date: Ref. Pt. Method Reference Outage Elevation Observations N. Side Elevation (ft) (ft) (ft AMSL) A = Conductivity Probe (Water From 4Q08 Survey Level Indicator) and as amended by Ensure reporting is in datum Previous physical changes to 5 /time consistent with reference Outage, ft. B = Sounding locations Nov. 2011 elevation survey. measured Device 1/ B 1393.78 2” PVC cap

2/ A 1389.59 ½” Adptr

3/ A 1389.31 ½” Adptr

4/ B 1393.89 2” PVC Cap

5/ A 1391.91 ½” Adptr

8/ A 1389.95 2” PVC cap

9/ A 1388.12 ½” Adptr

10S/ A 1389.08 ½” Adptr

10N/ A 1390.51 ½” Adptr

11/ B 1388.57 2” PVC cap

12/ A 1387.04 ½” Adptr

13/ A 1386.99 2” PVC cap

14/ A 1388.40 Hole is inside cover

WP-91/ A 1390.05 2” PVC cap

ENV004.06 A1 of 1 File #30111-0001

This page intentionally left blank.

West Valley Site Management Program Page 1 of 6 ENVIRONMENTAL MONITORING PROCEDURE 01/29/2013

TITLE: Groundwater Elevation Measurements ENV006.02

1.0 PURPOSE

This procedure establishes the methods for measuring, recording, and reporting quarterly groundwater elevations at the State-Licensed Disposal Area (SDA).

2.0 SCOPE

This procedure describes the:  Methods for measuring quarterly groundwater elevations  Requirements for performing quarterly external well inspections  Minimum health and safety requirements for the work

3.0 EQUIPMENT

3.1 Groundwater Elevation Measurements - water level indicator (200-ft. cable minimum), electronic readout device (for use with dedicated conductivity probes), disposable gloves, plastic trash bags, analyte-free deionized (DI) water in a spray bottle and paper towels. 3.2 Field Documentation - Water Elevation Field Record (Attachment B), field logbook and calculator.

4.0 DEFINITIONS

4.1 Bailer: A specially designed tube installed in several 1100-series wells at the SDA for the purpose of collecting groundwater samples. 4.2 Bladder pump: A submersible pump installed in several 1100-series wells at the SDA for the purpose of collecting groundwater samples. 4.3 Dedicated conductivity probe: A conductivity probe attached to a graduated cable that is permanently installed in a contaminated well and used to measure groundwater levels. 4.4 Documenter: The worker who is recording the measurements in writing. 4.5 Electronic readout device: A battery-operated audio and visual indicator that, when connected to a dedicated conductivity probe, completes the circuit and signals the depth where the probe contacts water. 4.6 Measurer: The worker who is taking the physical measurements. ENV006.02 Page 2 of 6

4.7 Outage: The distance measured from a point of known elevation (i.e., a surveyed reference point) on a monitoring well, piezometer, etc., to the water surface in the well. 4.8 State-Licensed Disposal Area (SDA): A management area consisting of:  A 15-acre landfill containing radioactive and hazardous wastes in 14 disposal trenches.  Three closed and filled lagoons.  The T-1 building, containing storage facilities for both clean supplies and solid wastes generated from SDA activities (both contaminated and potentially contaminated solid wastes stored temporarily pending analysis).  The Frac Tank Building, containing never-used frac tanks and storage facilities for clean supplies. 4.9 Water level indicator - A battery-operated audio and visual indicator connected to a conductivity probe attached to a graduated cable and used to measure groundwater levels in uncontaminated wells at the SDA. 4.10 Well - Any 1100-series well, piezometer, slit-trench well (SMW), or borehole at the SDA (for the purposes of this procedure).

5.0 HAZARDS, SAFETY CONTROLS AND TRAINING

All personnel performing work activities in and around the SDA must be aware of the hazards associated with these activities, and use the appropriate precautions and controls to avoid exposure, injury or illness. Safety documentation (i.e., Hazard Identification Form and Industrial Work Permit [IWP]) must be prepared for the work in accordance with WVSMP Task Specific Safety Evaluations, HAS010. The Hazard Identification Form identifies the hazards that may be encountered while performing groundwater elevation measurements at the SDA. The IWP also establishes precautions and controls used to protect workers from these identified facility hazards, including health and safety training requirements and other required safety documentation (i.e., the site-specific health and safety plan). Information concerning SDA and Retained Premises hazards and safety controls are also described in the WVSMP Annual Site Specific Training, which is required for all those performing work at the SDA. All personnel performing groundwater elevation measurements must sign the current IWP prior to performing work.

6.0 QUALITY REQUIREMENTS

The key quality requirements applicable to the measurement of groundwater elevations are described below. These requirements have been integrated into this procedure. 6.1 Each groundwater elevation will be measured with respect to a consistent, predetermined reference location that has been surveyed and approved by the NYSERDA Project Manager. 6.2 Groundwater elevations will be determined using measuring devices with graduated cables whose accuracy has been verified to a secondary standard of length accurate to at least 0.01 foot. 6.3 Groundwater elevation measurements will be double-checked in the field, at a minimum, to ensure accuracy and reproducibility. At a minimum, measurements will also be checked in the field against the measurements of the previous round to ensure comparability. 6.4 Individuals performing the work will verify each other's work for accuracy and completeness. ENV006.02 Page 3 of 6

7.0 PROCEDURE

7.1 Instrument and Equipment Calibration, Operation and Maintenance 7.1.1 Ensure that the portable water level indicator has been calibrated against a secondary standard of length to be accurate to at least 0.01 foot (the manufacturer will likely affirm this in the documentation provided with the instrument). If subsequent repairs or adjustments are made to the instrument, the accuracy of the instrument will be verified and documented in the project files and/or field logbook prior to field work. 7.1.2 Operate and maintain instruments and equipment in accordance with the manufacturer's guidelines and recommendations. 7.1.3 Inspect field instruments and equipment approximately twice daily while in use - once during setup or first use and again before returning instruments/equipment to storage at the end of the day. Inspect for damage and serviceability. Record any preventative maintenance in the field logbook and/or the instrument-specific logbook or reference file. 7.1.4 Test the water level indicator before use by pressing the side button to ensure an audible tone and a functioning indicator light. Adjust the sensitivity control as necessary to adjust the response. If a large adjustment is necessary (compared to previous uses), or if sensitivity changes during the measurement round, investigate possible causes (e.g., conductivity probe may be dirty, weak batteries, etc.) and correct the problem. Record any significant changes in the field logbook. 7.1.5 Test the electronic readout device before each use by pressing the test button to ensure an audible tone and a functioning indicator light. Adjust the sensitivity control as necessary to adjust the response (Setting 3 is usually adequate). 7.1.6 If any instrument or equipment is in need of off-site service, send it for such service as soon as possible and arrange for backup equipment as necessary. 7.1.7 If an instrument does not pass its inspection or performance check or is otherwise found to be in need of off-site service, do not use the instrument for reportable measurements unless the service need does not affect data quality (e.g., a broken cable reel on the water level indicator). 7.1.8 Store the water level indicator and electronic readout device in a climate-controlled environment such as the vestibule between the SDA Frac Tank and T-1 Buildings.

7.2 Equipment Decontamination Rinse the portable water level indicator cable with analyte-free DI water after use at each well or piezometer to prevent cross-contamination between locations and help ensure the safety of personnel.

7.3 Groundwater Elevation Measurements The following steps will be used to measure quarterly groundwater elevations at the 21 1100-series wells, 18 piezometers, nine slit-trench monitoring wells (SMWs), and one borehole (B-14) listed on the Water Elevation Field Record (Attachment B), all of which are shown on Figure 1 (Attachment A). The portable water level indicator will be used at the locations without dedicated conductivity probes. The electronic readout device will be used at locations with dedicated conductivity probes as indicated on the Water Elevation Field Record (Attachment B). ENV006.02 Page 4 of 6

7.3.1 General 7.3.1.1 Schedule quarterly groundwater elevation measurements within seven days of the West Valley Demonstration Project (WVDP) quarterly water elevation measurement event. Schedule the SDA groundwater and leachate elevation measurements for the same day. 7.3.1.2 Set up a new Water Elevation Field Record (Attachment B) for each quarterly event by recording the previous quarter's groundwater level (outage) and external well inspection observations. 7.3.1.3 Ensure that the measurer wears disposable gloves during all water elevation measurements and changes gloves between locations to prevent cross-contamination. 7.3.1.4 Ensure that any loose objects are kept away from the well to prevent them from inadvertently falling into and/or damaging or contaminating the well. 7.3.2 Groundwater Elevation Measurement - No Dedicated Conductivity Probes

7.3.2.1 Locate the well and confirm its position on the site location map in Figure 1 (Attachment A). 7.3.2.2 Unlock and open the well. 7.3.2.3 At 1100-series wells with installed bladder pumps, carefully lift the pump assembly ring off the top of the inner well casing in order to access the top of the inner casing. At 1100-series wells with installed bailers, remove the bailer and either have a team member hold it or lay it down on a clean piece of plastic. Allow the water level to stabilize for about a minute prior to measurement. 7.3.2.4 The measurer will lower the probe of the portable water level indicator into the well until a steady audio tone is heard and the red indicator light is on, indicating that the probe has contacted groundwater. Raise and lower the probe to confirm the depth at which the continuous tone is heard. 7.3.2.5 Measure the depth to groundwater to the nearest 0.01 foot with respect to the reference location noted on the Water Elevation Field Record (Attachment B), and against the north side of the well. Repeat and confirm the measurement and announce it to the documenter. The documenter will note whether the measurement conforms to the following general criteria:  Shallow and intermediate wells and piezometers (i.e., those except for the 1100-series "C" wells) - within 0.5 feet of the previous quarter's measurement.  Deep wells (i.e., the 1100-series "C" wells) - within 0.02 feet of the previous quarter's measurement. Measure the water level a third time if the above criteria are not met. The documenter will either perform the third measurement (after donning disposable gloves) or confirm that the measurer is performing the third measurement accurately. If the criteria are not met after the third measurement, the field team will convey that information to the NYSERDA Project Manager immediately. 7.3.2.6 Record the confirmed measurement on the Water Elevation Field Record (Attachment B). Note on the log all cases when a third confirmatory measurement was made. 7.3.2.7 Remove the probe from the well by winding the water level indicator reel. To decontaminate the cable, spray it with analyte-free DI water as it is rewound. ENV006.02 Page 5 of 6

7.3.2.8 Reseat the pump assembly ring or reinstall the bailer in the well, as applicable. Close and lock the well. 7.3.2.9 Repeat the above steps for other wells without dedicated downhole probes. The documenter and measurer should provide frequent oversight of each other's work to ensure accuracy, reproducibility and comparability. 7.3.3 Groundwater Elevation Measurement - Dedicated Conductivity Probes

7.3.3.1 Locate the well and confirm its position on the site location map in Figure 1 (Attachment A). 7.3.3.2 Unlock and open the well. 7.3.3.3 Attach the electronic readout device to the amphenol connector at the top of the graduated cable (coiled at the top of the well). Release the excess cable stored at the top of the well by undoing the releasable cable tie. Be sure to have a firm hold of the cable as it is released so that the cable and attached dedicated conductivity probe do not relax into the well unaided. (The cable is prevented from falling into the well by two mechanisms: a retaining ring situated at the top of the well, and by loosely coiling a large amount of excess cable at the top of the well. Attaching the readout device to the top end of the cable before releasing it will further ensure that the cable will not fall into the well.) Caution: Do not raise any part of the downhole portion of the cable above the retaining ring. The downhole portion of the cable is considered to be potentially contaminated and should be avoided. 7.3.3.4 The measurer will gently lower the cable into the well until a steady audio tone is heard and the indicator light is on, indicating that the dedicated conductivity probe has contacted groundwater. Raise and lower the cable to confirm the depth at which the continuous tone is heard. 7.3.3.5 Measure the depth to groundwater to the nearest 0.01 foot with respect to the reference location noted on the Water Elevation Field Record (Attachment B) and against the north side of the well. Repeat and confirm the measurement and announce it to the documenter. The documenter will note whether the measurement is within about 0.5 feet of the previous quarter's result. Measure the water level a third time if the measurement is not within about 0.5 feet of the previous quarter's result. The documenter will either perform the third measurement (after donning disposable gloves) or confirm that the measurer is performing the third measurement accurately. If the criteria are not met after the third measurement, the field team will convey this information to the NYSERDA Project Manager immediately. 7.3.3.6 Record the confirmed measurement on the Water Elevation Field Record (Attachment B). Note on the log all cases when a third confirmatory measurement was made. 7.3.3.7 Raise the cable slightly such that the dedicated conductivity probe is suspended at least 0.5 feet above the water line. Recoil the excess cable at the top of the well and resecure it with the releasable cable tie. Ensure that the retaining ring is securely seated and the coiled cable is firmly situated above the ring. 7.3.3.8 Close and lock the well. 7.3.3.9 Repeat the above steps for other wells with dedicated conductivity probes. The documenter and measurer should provide frequent oversight of each other's work to ensure accuracy, reproducibility and comparability. ENV006.02 Page 6 of 6

7.4 External Well Inspection and Maintenance During the quarterly groundwater elevation measurement work, note the external condition of each well, including, but not limited to, inspecting well pads, outer well casings, locks and well identification labels. Compare the observations with those of the previous quarter. Record the observations on the Water Elevation Field Record (Attachment B), along with any maintenance needs and maintenance performed during the work.

7.5 Field Documentation 7.5.1 Complete the Water Elevation Field Record (Attachment B) and double-check the entries for accuracy and completeness before leaving the site. This form should be a permanent part of the field records and should be maintained with the field logbook in the project files. 7.5.2 Document field activities in the field logbook in accordance with E&E Field Activity Logbooks1. Reference in the logbook any forms or data sheets used to record field information (e.g., the Water Elevation Field Record [Attachment B]). The information on the Water Elevation Field Record does not need to be duplicated in the field logbook. 7.5.3 Make corrections to field documentation by drawing a single line through the original entry (so that the original entry can still be read), and write the corrected entry alongside. Corrections must be initialed and dated.

8.0 RECORD KEEPING

The project team will:  Provide the original completed Water Elevation Field Record (Attachment B) and field logbook to the NYSERDA Project Manager.  Maintain a copy of the Water Elevation Field Record (Attachment B) and field logbook in the project files.

9.0 ATTACHMENTS

Attachment A: Figure 1 - Water Elevation Measurement Locations (one page) Attachment B: Water Elevation Field Record (three pages)

1 Ecology and Environment, Inc., Field Activity Logbooks, DOC 2.1, Lancaster, New York, 1998.

ATTACHMENT A Figure 1 – Water Elevation Measurement Locations

This page intentionally left blank. Attachment A

Figure 1: Water Elevation Measurement Locations

ENV006.02 A-1

This page intentionally left blank.

ATTACHMENT B Water Elevation Field Record

This page intentionally left blank.

Attachment B – Water Elevation Field Record

Water Level Measurements and Observations - ______Quarter 20______

Water Level Water Level External Inspection Results Notes/Comments Inner Casing Measurement Measurement Well Time Reference Point (ft TOIC) (ft TOIC) (N. side) Date: Date: Date: Date: 1101A Permanent PVC apparatus on inner casing (slide disk aside) 1101C SS 1101B SS 1102A SS 1102B SS 1103A SS 1103B SS 1103C SS 1104A SS 1104B SS 1104C SS 1105A SS 1105B SS 1106A SS 1106B SS 1107A SS 1108A SS 1109A SS 1109B SS 1110A SS 1111A SS 1S-91 Alum. Ring 2S-91 Alum. Ring ENV006.02 B-1 Central File # 30105-0002 Attachment B – Water Elevation Field Record

Water Level Measurements and Observations - ______Quarter 20______

Water Level Water Level External Inspection Results Notes/Comments Inner Casing Measurement Measurement Well Time Reference Point (ft TOIC) (ft TOIC) (N. side) Date: Date: Date: Date: 3S-91 Alum. Ring 4S-91 Alum. Ring 4D-91 Alum. Ring 6S-91 Alum. Ring (Ded’d probe) 6D-91 Alum. Ring 9S-91 Alum. Ring (Ded’d probe) 9D-91 Alum. Ring (Ded’d probe) 10S-91 Alum. Ring 15S-91 Alum. Ring (Ded’d probe) 16D-91 Alum. Ring 17S-91 Alum. Ring (Ded’d probe) 18S-91 Alum. Ring (Ded’d probe) 21S-91 Alum. Ring (Ded’d probe) 22S-91 Alum. Ring (Ded’d probe) 24S-91 Alum. Ring B-14 SS (inner casing (Ded’d probe) plate) P1-95 Single metal

ENV006.02 B-2 Central File # 30105-0002 Attachment B – Water Elevation Field Record

Water Level Measurements and Observations - ______Quarter 20______

Notes for dry wells/total depth measurements: Old Solinst probe dead end – 0.28 ft. New Solinst probe dead end = 0.28 ft. Dedicated probes dead ends unknown; use measured result “as is”.

Field Team Personnel:

Primary Measurer Primary Documenter

ENV006.02 B-3 Central File # 30105-0002 West Valley Site Management Program Page 1 of 19 ENVIRONMENTAL MONITORING PROCEDURE 01/29/2013

TITLE: Groundwater Sampling ENV007.01

1.0 PURPOSE

This procedure establishes the methods for collecting groundwater samples from the 21, 1100-series wells or other wells and piezometers located at the State-Licensed Disposal Area (SDA).

2.0 SCOPE

This procedure:

 Defines the methods for sampling groundwater for radiological, chemical and water quality constituents as applicable.  Describes requirements for sample containers, sample volumes, preservatives and field quality control (QC) samples.  Defines the methods for sample identification and labeling, and field documentation.  Describes the requirements for the biennial internal well inspection and measurement of total well depth.  Describes health and safety evaluation/documentation requirements for the work.

This procedure does not address sample custody, packaging, and transport, which are addressed in NYSERDA’s procedure ENV008, Field Sample Management.

3.0 EQUIPMENT AND SUPPLIES

3.1 Pumping, Purging and Sampling – Down-hole dedicated bladder pumps (14 wells), dedicated bailers (seven wells), pump compressor and engine, gas for compressor engine, pump controller box, graduated purge bucket, in-line 0.45-micron filters, disposable 0.45-micron barrel filters, vacuum pump (for using barrel filters), 200-foot water level indicator, analyte-free deionized water (DI), disposable gloves, paper towels, sample containers (certified pre-cleaned), coolers or boxes (to carry sample bottles and samples), ice and sample preservatives.

3.2 Water Quality Measurements - YSI 556 Multi-Parameter System (MPS) water quality meter or equivalent (for pH, conductivity, and temperature); separate YSI measurement cup; Hach turbidimeter or equivalent; calibration standards; and Water Quality Calibration Log.

3.3 Sample Identification and Field Documentation - Sample labels, Well Sampling Log and field logbook. ENV007.01 Page 2 of 19

4.0 DEFINITIONS

4.1 Field Duplicate Sample - A field and analytical QC sample collected to measure and assess field and analytical precision (reproducibility). The field duplicate is collected in the same location, at the same time, and in the same manner as the original field sample.

4.2 Matrix Spike/Matrix Spike Duplicate (MS/MSD) Sample - A field and analytical QC sample collected to measure and assess the effects of the sample matrix on analytical accuracy and precision. MS/MSD sample volumes collected in the field are spiked in the laboratory with known quantities of target analytes. The recoveries of the analytes in the MS and MSD samples are assessed to determine accuracy, and the relative quantities of the analytes between the MS and MSD samples are assessed to determine precision.

4.3 Pump Controller Box - A pneumatic pump cycle controller used to regulate air supplied from the compressor to operate a submersible bladder pump.

4.4 State-Licensed Disposal Area (SDA) - A management area consisting of:

 A 15-acre landfill containing radioactive and hazardous wastes in 14 disposal trenches.  Three closed and filled lagoons.  The T-1 Building, containing storage facilities for both clean supplies and solid wastes generated from SDA activities (both contaminated and potentially contaminated solid wastes stored temporarily pending analysis).  The Frac Tank Building, containing never-used Frac tanks and storage facilities for clean supplies. 4.5 Temperature Blank - A field QC sample prepared to track and measure the temperature at which collected samples are maintained during on-site handling and transportation to the laboratory.

4.6 Trip Blank Sample - A field QC sample prepared to measure whether contamination has been introduced during transport. For this program, the trip blank sample will be used to determine whether contamination has been introduced during transport of the clean volatile organics analysis (VOA) sample vials and analyte-free DI water to the site, as well as during transport of the collected volatile organic compound (VOC) samples from the site to the laboratory.

4.7 Water Level Indicator - A battery-operated audio and visual indicator connected to a conductivity probe attached to a graduated cable used to measure groundwater levels in uncontaminated wells at the SDA. 4.8 Well – Any 1100-series or other well at the SDA (for the purposes of this procedure).

ENV007.01 Page 3 of 19

5.0 HAZARDS, SAFETY CONTROLS AND TRAINING

All personnel performing work activities in and around the SDA must be aware of the hazards associated with these activities, and use the appropriate precautions and controls to avoid exposure, injury or illness. Safety documentation (i.e., Hazard Identification Form and Industrial Work Permit [IWP]) must be prepared for the work in accordance with WVSMP Task Specific Safety Evaluations, HAS010. The Hazard Identification Form identifies the hazards that may be encountered while performing groundwater sampling activities at the SDA. The IWP also establishes precautions and controls used to protect workers from these identified facility hazards, including health and safety training requirements and other required safety documentation (HAS503, Safety and Health Program Plan). Information concerning SDA and Retained Premises hazards and safety controls are also described in the WVSMP Annual Site Specific Training, HAS005, which is required for all individuals working at the SDA. All personnel performing groundwater sampling activities must sign the current IWP prior to performing work.

6.0 QUALITY REQUIREMENTS

The key quality requirements applicable to the field collection of groundwater samples are described below.

6.1 The groundwater monitoring program shall be conducted in accordance with:

 The guidance in the Multi-Agency Radiological Laboratory Analytical Protocols Manual (MARLAP)1; EPA QA/G-8, Guidance on Environmental Data Verification and Data Validation2; EPA QA/R-5, EPA Requirements for Quality Assurance Project Plans3; and the NYSDEC, RCRA Quality Assurance Project Plan Guidance4.

 Applicable analytical and sampling methods identified in The Procedures Manual of the Environmental Measurements Laboratory5, U.S. DOE (HASL-300), and Test Methods for Evaluating Solid Waste, Physical/Chemical Methods6, U.S. EPA (SW-846).

Applicable or pertinent requirements have been integrated into this procedure.

1 U.S. Environmental Protection Agency, et al., Multi-Agency Radiological Laboratory Analytical Protocols Manual, Washington, DC, 2004. 2 EPA, Guidance on Environmental Data Verification and Data Validation, EPA QA/G-8, Washington, DC, 2002. 3 EPA, EPA Requirements for Quality Assurance Project Plans, EPA QA/R-5, Washington, DC, 2001. 4 New York State Department of Environmental Conservation, RCRA Quality Assurance Project Plan Guidance, Albany, New York, 1991. 5 U. S. Department of Energy, The Procedures Manual of the Environmental Measurements Laboratory, HASL- 300, Volume 1, 28th Edition, New York, New York, 1997. 6 EPA, Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, SW-846, Third Edition, Washington, DC, 1996. ENV007.01 Page 4 of 19

6.2 Field QC samples will include:

 Field duplicate - Collected each semiannual sampling round and analyzed for the parameters typically scheduled for that round. The well selected for field duplicate sampling should be varied between sampling rounds.

 Matrix spike/matrix spike duplicate (MS/MSD) - Collected each semiannual sampling round for parameters suitable for MS/MSD testing (e.g., tritium, VOCs).

 Trip blank - Collected each sampling round that groundwater samples are collected for VOC analysis, and analyzed for VOCs.

 Temperature blank – Prepared for each cooler of samples required to be cooled to 4° C during on- site storage and off-site transportation to the laboratory.

Specific requirements for field QC samples are included in Section 7.5.

6.3 Certified pre-cleaned sample containers will be used.

7.0 PROCEDURE

7.1 Instrument and Equipment Calibration, Operation and Maintenance

7.1.1 General

7.1.1.1 Operate, calibrate, and maintain instruments and equipment in accordance with the manufacturer’s guidelines and recommendations.

7.1.1.2 Inspect field instruments and equipment at least twice daily while in use—once during calibration or first use, and again before returning instruments/equipment to storage at the end of the day. Record preventative maintenance in the groundwater field logbook, and/or the instrument-specific calibration sheet or reference file.

7.1.1.3 If an instrument does not pass its field calibration or performance check or has been otherwise found to be in need of off-site service, do not use the instrument for reportable measurements unless necessary (e.g., when a backup unit is not immediately available). Flag each measurement made under those circumstances so the measurements can be evaluated later for quality.

7.1.1.4 If an instrument or equipment is in need of off-site service, send it for such service as soon as possible and arrange for a back-up unit as necessary.

7.1.1.5 Maintain instruments such as the water level indicator, the YSI 556, and turbidimeter, and their calibration standards and supplies, in a climate-controlled environment such as the SDA facilities vestibule when not in use. Remove batteries prior to long-term storage. ENV007.01 Page 5 of 19

7.1.2 YSI 556 MPS

7.1.2.1 When calibrating the YSI 556 MPS, also do the following:

7.1.2.1.1 - Obtain fresh pH and conductivity standards for each semiannual sampling round. Retain the last round’s standards as backup in case of spillage or other problems that may occur during the sampling round. (Note: the conductivity standard has a shelf-life of 30 days after opening. Conductivity standards past 30 days old should be discarded.)

7.1.2.1.2 - Obtain and install a new pH probe every one to two years of sampling, in accordance with the manufacturer’s recommendations.

7.1.2.1.3 - Refer to the supplemental guidelines stored with the operating manual.

7.1.2.1.4 - Equilibrate the conductivity sensor from its dry storage state, as necessary, by immersing it in DI water (or tap water, if the pH probe is attached) for at least 30 minutes prior to calibration and use.

7.1.2.1.5 - Apply real-time temperature corrections for pH and conductivity in accordance with the operating manual.

7.1.2.1.6 - Record calibration results on the Water Quality Calibration Log (Attachment B).

7.1.2.2 Transport the YSI probe module in the transport/calibration cup with enough tap water to cover the ends of the sensors to keep them from drying out.

7.1.2.3 Use the probe sensor guard to protect the sensors when they are not used with the flow-through cell.

7.1.2.4 When measuring pH, conductivity, and temperature during purging and sampling, operate the instrument in accordance with the operating manual and the supplemental guidelines stored with the manual.

7.1.2.5 Ensure that readings have stabilized before recording them.

7.1.3 Turbidimeter

7.1.3.1 When calibrating the turbidimeter, also do the following:

7.1.3.1.1 - Calibrate the turbidimeter in accordance with the manufacturer’s secondary calibration check procedures (the turbidimeter receives its primary [formazin] calibration at the rental facility or service shop). It is preferable to use the gel-form standards (versus powder standards) for the in-field calibration check. When using gel standards, turbidity readings should be within approximately 50 percent of the gel-form standard reference value.

7.1.3.1.2 - If the field check indicates variance of >5 percent between the reference standard value (allowing for the 50 percent difference for gel-form standards) and the instrument reading, submit the unit to the manufacturer or approved calibration facility for primary recalibration.

7.1.3.1.3 - Record calibration results on the Water Quality Calibration Log (Attachment B). ENV007.01 Page 6 of 19

7.1.3.2 When measuring turbidity during purging and sampling, operate the instrument in accordance with the operating manual. Use a clean, unscratched and externally dry sample cell.

7.1.4 Portable Water Level Indicator

7.1.4.1 Ensure that the portable water level indicator has been calibrated against a secondary standard of length to be accurate to at least 0.01 foot (the manufacturer will likely affirm this in the documentation provided with the instrument). If subsequent repairs or adjustments are made to the instrument, the accuracy of the instrument will be verified and documented in the project files and/or field logbook prior to field work.

7.1.5 Pump Compressor and Engine

7.1.5.1 Fill the engine with gas only on the concrete pad outside of the Frac Tank Building. Do not refill gas at the SDA well locations.

7.1.5.2 Prior to use, check fluid levels and check the engine and compressor for leaks, damage and wear.

7.1.5.3 Run the engine out of gas and empty the gas bulb for long-term storage.

7.1.5.4 Take the unit off site at least biennially for an oil change and servicing (e.g., spark plug and air cleaner change-out; inspection of belts and connections, etc.).

7.1.6 Pump Controller Box

7.1.6.1 Inspect the controller box for damage prior to use. Inspect air hoses for cracks and damage.

7.1.6.2 Store the controller box in the SDA vestibule with the case opened to drain moisture.

7.1.6.3 Take the controller box off site approximately biennially for servicing (e.g., air filter change-out and internal valve inspection).

7.2 Equipment Decontamination

Ensure that reusable equipment used for groundwater sampling is decontaminated before and after use, and between different samples in accordance with the methods below.

7.2.1 When using the YSI flow-through cell when purging a well, flush the cell with at least 500 milliliter (mL) of purge water from the well before recording purge measurements. (The flow-through cell does not have to be decontaminated with DI water between wells because it is only used during purging; water samples and water for reportable water quality parameters are not passed through it.)

7.2.2. Rinse the YSI sensor unit (pH, conductivity, and temperature probes) with tap water or analyte-free DI water, or triple rinse with the sample water to be measured, before measuring reportable water quality. (Do not subject the pH sensor to prolonged contact with DI water, which can adversely affect the sensor.)

7.2.3 Rinse the separate YSI measurement cup and turbidity cell with analyte-free DI water between samples and before using to measure reportable water quality. ENV007.01 Page 7 of 19

7.2.4 Rinse the water level indicator tape with analyte-free DI water between wells.

7.2.5 Rinse any other reusable equipment and supplies with analyte-free DI water between use for samples or reportable measurements from different wells.

7.3 Well Purging

The following steps will be used to purge the 1100-series wells in preparation for sampling. Figure 1 in Attachment A shows the locations of the 1100-series wells.

Caution: Do not purge Well 1109B before purging and sampling Well 1109A. The two wells are hydraulically connected.

7.3.1 General

7.3.1.1 Set up a Well Sampling Log for each well (Attachment C).

7.3.1.2 To determine the proper purge volume for each well, measure the water level at each well or use the most recent quarterly elevation measurements if they are current. To measure the water level:

7.3.1.2.1 - Locate the well and confirm its position on the site location map in Figure 1. Unlock and open the well. 7.3.1.2.2 - At 1100-series wells with installed bladder pumps, carefully lift the pump assembly ring off the top of the inner well in order to access the top of the inner casing. At 1100-series wells with installed bailers, remove the bailer and either have a team member hold it or lay it down on a clean piece of plastic; allow the water level to stabilize for approximately one minute prior to measurement. 7.3.1.2.3 - Lower the probe of the portable water level indicator into the well until a steady audio tone is heard and the red indicator light is on, indicating that the probe has contacted groundwater. Raise and lower the probe to confirm the depth at which the continuous tone is heard. 7.3.1.2.4 - Measure the depth to groundwater from the top of the stainless steel inner well casing. Confirm the measurement and document it on the Well Sampling Log. 7.3.1.2.5 - Decontaminate the water level indicator cable by spraying it with analyte-free DI water as it is rewound from the well. 7.3.1.2.6 - Use the water level measurements and the most recent total well depths (measured biennially) to calculate the static height of the water in the well as follows: Static water height (feet) = Total depth (in feet measured from top of inner casing [TOIC] or other approved reference point) -water level (in feet measured TOIC) 7.3.1.2.7 - Calculate the static water volume for each two-inch-diameter well as follows: Static water volume (gallons) = Static water height (feet) x 0.163 gal/foot Multiply the static water volume by three to result in the purge volume for each well. Record this information on the Well Sampling Log. ENV007.01 Page 8 of 19

7.3.1.3 Determine the estimated frequency for obtaining purge water quality measurements based on the calculated purge volume. Water quality will be measured at the beginning of purging, several times throughout purging (every gallon or gallon-and-a-half of purge water, depending on the available purge volume), and at the end of purging.

7.3.1.4 Don disposable gloves (worn for all purging activities and changed between sample locations to prevent cross-contamination).

7.3.1.5 Ensure that loose objects are kept away from the well so they do not fall in, and damage or contaminate the well.

7.3.2 Purging Wells with Bladder Pumps

These steps apply to Wells 1101A, 1B, 2A, 2B, 3A, 3B, 4A, 4B, 6A, 6B, 7A, 9A, 9B and 11A.

7.3.2.1 Unlock and open the well if not done so already.

7.3.2.2 Set up the pump compressor and pump controller box. Ensure that the compressor is downwind of the well to prevent contaminating the well with engine exhaust. Attach the air hose from the wellhead to the controller box, and from the controller box to the compressor.

7.3.2.3 Connect the YSI flow-through cell in series with the sample discharge tubing. Insert the probe unit into the top of the flow-through cell. Run the YSI discharge tubing into the graduated purge bucket. Set up the turbidimeter.

7.3.2.4 Verify that the airline isolation valve at the controller is closed. Start the compressor.

7.3.2.5 Open the airline isolation valve on the controller to begin cycling air through the bladder pump, and adjust the discharge and refill rates to control the pumping rate. The pumping rate should not exceed 500 mL/min, which is the limitation of the YSI flow-through cell. Note the pumping rate by observing the discharge into the graduated bucket.

7.3.2.6 After at least 500 mL of purge water has passed through the flow-through cell, measure initial purge water quality (pH, conductivity, temperature) in accordance with the operating manual. At the same time, collect some purge water in the turbidity cell and measure turbidity in accordance with the operating manual. Record the initial measurements on the Well Sampling Log (Attachment C).

7.3.2.7 Continue purging. Measure and record water quality throughout purging in accordance with the operating manual for the YSI 556 MPS and the Turbidimeter, and the estimated frequency determined in operating manual as well. Use the graduated bucket to measure the volume purged.

7.3.2.8 Purge the calculated three well volumes or to dryness, whichever comes first. Observe the flow discharged with each pump cycle to determine when recovery is slowing down. Do not over-purge the well. After measuring the volume purged, discard purge water to the ground surface in the vicinity of the well. Measure and record water quality at the end of purging.

7.3.2.9 Complete the purging portion of the Well Sampling Log. ENV007.01 Page 9 of 19

7.3.2.10 When done purging at the well, disconnect the air hoses and YSI tubing, and close and lock the well.

7.3.3 Purging Wells with Bailers

These steps apply to Wells 1101C, 5A, 5B, and 8A. Do not purge Wells 1103C, 4C, and 10A due to low recharge rates.

7.3.3.1 Unlock and open the well if not done so already.

7.3.3.2 Set up the YSI meter, without flow-through cell, and the turbidimeter.

7.3.3.3 Lower the bailer into the well. Gently raise and lower the bailer to allow it to fill from the bottom check-ball assembly. Raise the bailer.

7.3.3.4 Pour some of the initial purge water into the separate YSI measurement cup. Immerse the YSI probe unit into the water, being sure to fully cover the sensors. Measure initial purge water quality (pH, conductivity, temperature) in accordance with the operating manual. At the same time, collect some purge water in the turbidity cell and measure turbidity in accordance with operating manual. Record the initial measurements on the Well Sampling Log (Attachment C). Discard the purge water into the graduated purge bucket.

7.3.3.5 Continue purging via bailing. Measure and record water quality throughout purging in accordance with instructions in the respective operating manuals, and the estimated frequency determined in Step 7.3.1.3 in the operating manual. Use the graduated bucket to measure the volume purged.

7.3.3.6 Purge the calculated three well volumes or to dryness, whichever comes first. Note the amount of water obtained with each bail to determine when recovery is slowing down. Do not over-purge the well. After measuring the volume purged, discard purge water to the ground surface in the vicinity of the well. Measure and record water quality at the end of purging.

7.3.3.7 Complete the purging portion of the Well Sampling Log.

7.3.3.8 When done purging at the well, suspend the bailer in the well above the water line and close and lock the well.

7.4 Sampling Wells

The following steps will be used to collect groundwater samples at SDA wells. Figure 1 shows the locations of the wells. Table 7-1 (found on page 11) shows the sampling and analysis summary, including required analyses, container types, QC samples, ideal and minimum sample volumes and preservatives.

Caution: Do not transport the pump compressor or gasoline in the interior of the field vehicle with empty VOA vials, DI water, or collected VOC samples in order to prevent their contamination from gasoline fumes.

7.4.1 General

7.4.1.1 Sample within three hours of purging if recharge is sufficient to accommodate sample collection for all required parameters; otherwise, sample within 24 hours of purging for as many parameters as can be collected. ENV007.01 Page 10 of 19

Typically, for the second quarter round, each well is purged in the afternoon and sampled the next morning. For the fourth quarter round, each well is purged and sampled in direct sequence.

7.4.1.2 Sample in accordance with the following general analytical priorities:

 Tritium  VOCs  Gross alpha, gross beta  Gamma spec  C-14, I-129, Sr-90, and Tc-99  Field water quality - pH, conductivity, temperature and turbidity

Adjust the priorities with each sampling round such that those parameters that were not collected on schedule in the past are moved up in priority behind gross beta. Use appropriate pre-cleaned sample containers.

7.4.1.3 Refer to Section 7.5 for instructions on the collection of applicable field QC samples (the schedule for QC samples is specified in Section 6.2 and Table 7-1).

7.4.1.4 Don disposable gloves (worn for all sampling activities and changed between sample locations to prevent cross-contamination).

7.4.1.5 Ensure that loose objects are kept away from the well so they do not fall in and damage or contaminate the well.

7.4.2 Sampling Wells with Bladder Pumps

These steps apply to the wells purged in Step 7.3.2.

7.4.2.1 Unlock and open the well.

7.4.2.2 Set up the pump compressor and pump controller box. Ensure that the compressor is downwind of the well to prevent contaminating the well and samples with engine exhaust. Attach the air hose from the wellhead to the controller box, and from the controller box to the compressor.

7.4.2.3 Attach the teflon sample discharge tubing at the wellhead.

7.4.2.4 Set up the YSI meter, without flow-through cell, and the turbidimeter.

7.4.2.5 Verify that the air-line isolation valve at the controller is closed. Start the compressor.

7.4.2.6 Open the air-line isolation valve on the controller to begin cycling air through the bladder pump, and adjust the discharge and refill rates to control the pumping rate.

ENV007.01 Page 11 of 19

Table 7-1 SDA Groundwater Sampling and Analysis Summary

Required Sample Field QC Samples Volume Extra Size and Ideal Min. Max. No. of Fld Trip a Vol. for Type of Vol. Vol. Holding Parameter Frequency Samples Dup Blk MS MSD a Lab Rep b Container (mL) (mL) Preserv. Time Radiological (Filtered)

f Gross alpha Semiannually 21 1 B B B 1 1-L poly 500 200 HNO3, pH <2 6 mo. f Gross beta Semiannually 21 1 B B B 1 1-L poly 500 200 HNO3, pH <2 6 mo. Tritium Semiannually 21 1 B 1 1 1 250-mL glass 100 50 None 6 mo. Gamma Spec (Cs- 137, Co-60, and K- Annually 21 1 B B B 1 1-L poly 2,000 500 HNO3, pH <2 6 mo. 40 at a minimum) Carbon-14 Annually 21 1 B 1 1 1 1-L poly 100 100 None 6 mo. Iodine-129 Annually 21 1 B 1 1 1 1-L poly 1,000 500 None 6 mo.

Strontium-90 Annually 21 1 B B B 1 1-L poly 1,000 400 HNO3, pH <2 6 mo.

Technetium-99 Annually 21 1 B B B 1 1-L poly 500 500 HNO3, pH <2 6 mo. Volatile Organic Compounds RCRA App. IX Annually 21 1 5 c 1 1 B 40-mL VOA 120 80 4C 7 days VOCs d Field Water Quality e Conductivity Semiannually 21 1 B B B B B B B B B pH Semiannually 21 1 B B B B B B B B B Temperature Semiannually 21 1 B B B B B B B B B Turbidity Semiannually 21 1 B B B B B B B B B ENV007.01 Page 12 of 19

a MS/MSD analyses may change at the discretion of Ecology & Environment, Inc. (E&E) and the laboratory. b Extra volume intentionally collected in the field for laboratory replicate analyses for the radiological parameters because the volume requirements for each radioanalysis are substantial. This volume will not be tracked as a separate field sample. c One per shipment per day. d Fifty-six selected RCRA Appendix IX VOCs; see GMP. e Measured in the field. f Gross alpha and gross beta volumes may be combined in one bottle.

Note: A temperature blank will be prepared and submitted with each cooler of samples required to be cooled to 4° C ENV007.01 Page 13 of 19

7.4.2.7 If there is enough water in the well to assure collection for tritium (the highest priority analyte), then collect the samples for VOC analysis first since they are second in priority, require a controlled (gentle) collection and are the only unfiltered collection. Use as gentle a pumping rate as is possible when sampling for VOCs. When collecting VOC samples, ensure that there is zero headspace in the samples. After closing the VOA vial, invert and tap the collected sample to check for air bubbles. Re-collect if air bubbles are observed. Place VOC samples in a cooler with ice.

7.4.2.8 Attach a 0.45-micron in-line filter at the end of the sample discharge tubing. Collect the sample portions that are required to be filtered (i.e., the radioanalytical portions). Mark an “F” on the bottle or sample label indicating that the sample was filtered. Discard the in-line filter after use at the well (the filters are dedicated and not reused between wells).

7.4.2.9 Use as gentle a pumping rate as is possible when sampling for volatile radiological constituents such as tritium.

7.4.2.10 Collect the minimum required sample volumes for all required parameters and then obtain the ideal volume as well recharge allows.

7.4.2.11 To measure water quality of the collected sample, ensure that the in-line filter has been removed and collect water in the separate YSI measurement cup. Immerse the YSI probe unit into the water, being sure to fully cover the sensors. Record pH, conductivity, and temperature for the collected sample on the Well Sampling Log. Also collect some water in the turbidity cell, measure turbidity with the turbidimeter and record it on the Well Sampling Log.

7.4.2.12 Observe the flow discharged with each pump cycle to determine when recovery is slowing down. Do not over-sample the well. If sampling is incomplete, return to the well once more during the sampling round to attempt to collect the ideal sample volumes.

7.4.2.13 Tightly cap each sample container and ensure that the cap is not cross-threaded with the bottle. Wipe off excess water.

7.4.2.14 Identify the sample by marking pertinent information on the bottle using permanent marker or by affixing the sample label to the bottle. Sample labeling is discussed in Section 7.7.

7.4.2.15 Complete the sampling portion of the Well Sampling Log. Record the volumes collected for each bottle type and analysis.

7.4.2.16 When sampling at the well is complete, disconnect the air hoses and sample tubing, and close and lock the well.

7.4.3 Sampling Wells with Bailers

These steps apply to the wells purged in Step 7.3.3.

7.4.3.1 Unlock and open the well.

ENV007.01 Page 14 of 19

7.4.3.2 Set up the YSI meter, without flow-through cell, and the turbidimeter.

7.4.3.3 Lower the bailer into the well. Gently raise and lower the bailer to allow it to fill from the bottom check-ball assembly. Raise the bailer.

7.4.3.4 Pour the sample water into the sample containers. Bail and pour gently when sampling for VOCs and volatile radiological constituents such as tritium. When collecting VOC samples, ensure that there is zero headspace in the samples. After closing the VOA vial, invert and tap the collected sample to check for air bubbles. Re-collect if air bubbles are observed. Place VOC samples in a cooler with ice.

7.4.3.5 Collect the minimum required sample volumes for all required parameters and then obtain the ideal volume as well recharge allows.

7.4.3.6 To measure water quality of the collected sample, pour water in the separate YSI measurement cup. Immerse the YSI probe unit into the water, being sure to fully cover the sensors. Record pH, conductivity, and temperature for the collected sample on the Well Sampling Log. Also collect some water in the turbidity cell, measure turbidity with the turbidimeter, and record it on the Well Sampling Log.

7.4.3.7 Observe the amount of water collected with each bail to determine when recovery is slowing down. Do not over-sample the well. If sampling is incomplete, return to the well once more during the sampling round to attempt to collect the ideal sample volumes.

7.4.3.8 Tightly cap each sample container and ensure that the cap is not cross-threaded with the bottle. Wipe off excess water.

7.4.3.9 Identify the sample by marking pertinent information on the bottle using permanent marker or by affixing the sample label to the bottle. Sample labeling is discussed in Section 7.7.

7.4.3.10 Complete the sampling portion of the Well Sampling Log. Record the volumes collected for each bottle type and analysis.

7.4.3.11 When sampling at the well is complete, suspend the bailer in the well above the water line, and close and lock the well.

7.4.3.12 Manually filter the samples in the Frac Tank Building as follows (the sample fractions being sent for radioanalysis require filtering):

7.4.3.12.1 - Perform filtering as soon as practicable following the completion of sample collection for that well.

7.4.3.12.2 - Set up a disposable barrel filter and line it with pre-filters to extend the life of the barrel filter. Attach the barrel filter to the vacuum pump.

7.4.3.12.3 - Gently pour the sample into the barrel (do not dislodge the pre-filters) and turn on the pump. Add more sample as water filters through. Toward the end of the volume in the sample

ENV007.01 Page 15 of 19

bottle, swirl the sample to remove solids from the side of the bottle. Pour the filtered sample back into the same sample bottle.

7.4.3.12.4 - Repeat Steps 1 through 3 until all of the sample for that well have been filtered. Replace the pre-filters as necessary throughout filtering. Discard the filter when through with that well.

7.4.3.12.5 - Mark an “F” on each bottle or sample label indicating that the sample was filtered.

7.5 Collecting and Preparing Field QC Samples

7.5.1 Field Duplicate Sample

7.5.1.1 Collect the field duplicate sample in accordance with the schedule and parameters in Section 6.2 and Table 7-1. Vary the location of the field duplicate sample between sampling rounds. Choose a well with good recharge capabilities such that it can accommodate the collection of an extra sample.

7.5.1.2 Collect the field duplicate at the same time and in the same manner as the original sample.

7.5.1.3 Filter, preserve and handle the field duplicate sample in the same manner as the original sample.

7.5.2 MS/MSD Sample

7.5.2.1 Collect the MS/MSD sample in accordance with the schedule and parameters in Section 6.2 and Table 7-1. Vary the location of the MS/MSD sample between sampling rounds. Choose a well with good recharge capabilities such that it can accommodate the collection of extra sample.

7.5.2.2 Collect the MS/MSD sample at the same time and in the same manner as the volume collected for those analyses for the original sample.

7.5.2.3 Filter, preserve and handle the MS/MSD sample in the same manner as the original sample.

7.5.3 Trip Blank Sample

7.5.3.1 Prepare trip blank samples in accordance with the schedule and parameters in Section 6.2 and Table 7- 1 (i.e., daily for VOC samples).

7.5.3.2 Prepare each trip blank sample by pouring analyte-free DI water into VOA vials that are from the same bottle lot as those used for the samples from the wells. Prepare the first trip blank sample of the sampling week prior to the first trip to the site and transport it with any clean VOA vials and analyte-free DI water being transported to the site so the blank can be used to determine whether contamination is introduced to the VOC samples on both legs of the trip (transport of empty VOA vials and DI water to the site, as well as transport of the collected VOC samples from the site to the laboratory). Prepare subsequent trip blank samples during the sampling week either at the analytical laboratory the night before sampling or in the field on the morning of sampling. Do not prepare the trip blanks too far in advance because they are subject to the same holding time requirements as the VOC samples (i.e., seven days).

ENV007.01 Page 16 of 19

7.5.3.3 Place the prepared trip blank sample in a cooler with ice and handle it throughout the day in the same manner as the VOC samples collected that day from the wells.

7.5.4 Extra Volume for Lab Replicate

7.5.4.1 Collect extra volume for the radioanalytical laboratory to use for lab replicate analyses in accordance with the schedule and parameters in Section 6.2 and Table 7-1. Vary the location of the lab replicate sample between sampling rounds. Choose a well with good recharge capabilities such that it can accommodate the collection of an extra sample.

7.5.4.2 Collect the lab replicate sample volumes at the same time and in the same manner as the original sample.

7.5.4.3 Filter, preserve, and handle the lab replicate sample in the same manner as the original sample.

7.5.5 Temperature Blank Sample

7.5.5.1 Prepare temperature blanks in accordance with the schedule and parameters in Section 6.2 and Table 7-1.

7.5.5.2 Prepare each temperature blank by pouring clean water (e.g., tap or DI water) into a 40-ml VOA vial.

7.5.5.3 Place a temperature blank in each cooler holding samples requiring cooling. Maintain the blank with the cooler throughout the period of sampling, sample handling, sample management, and transport to off-site laboratories.

7.6 Sample Preservation

7.6.1 Precaution - Before preserving samples, don protective apparel and eyewear in accordance with HAS503, WVSMP Safety and Health Program.

7.6.2 Preserve sample fractions with applicable preservatives as indicated in Table 7-1. Preserve samples as soon as practicable following filtration and after sampling has been completed for that well.

7.6.3 When adding preservative, use a disposable pipet to add preservative to the sample. Rule-of-thumb: approximately 4 to 5 mLs of nitric acid should be enough to lower the pH of about one liter of neutral water to <2. Be aware that adding too much preservative will unnecessarily dilute the sample.

7.6.4 Verify the pH of all samples collected for radiological analysis, not just those that have been preserved. (Do not verify the pH of the VOC samples because the integrity of the sample would be compromised by opening them.) To verify pH, use a clean disposable pipet to collect a drop of sample from the container (do not insert the pH paper into the sample container). Place the drop on pH indicator paper and record the observed pH on both the sample label and the Well Sampling Log.

ENV007.01 Page 17 of 19

7.7 Sample Identification and Labeling

7.7.1 Assign a unique sample ID to each sample using the following convention:

xxxx-50yzz Where: xxxx = calendar year 50 = fixed code signifying a groundwater sample ID y = calendar quarter (1, 2, 3 or 4) zz = sequential number (01 and up) Each Sample ID must be associated with only one sample date. Therefore, in cases where a well was sampled over more than one day in order to maximize the volume collected from it, assign the sample to the first date the well was sampled. (Use the Well Sampling Log to clarify which fractions were collected on which dates.)

Assign each field duplicate sample and trip blank sample its own unique sample ID. To the extent possible, those samples should appear to the laboratory as regular investigative samples. MS/MSD and lab replicate sample fractions do not have to be assigned a unique sample ID.

7.7.2 Apply a sample label that includes the following information:

 Sample ID  Sample Location ID  Job code  Collection date and time  Analyses required  Preservation used  Measured pH value  Whether the sample is an MS/MSD sample or lab replicate sample volume

Sample Location IDs are as follows: WNW1101A = Well 1101A WNW8101 = Trip blank 7.7.3 Cover the completed sample label with clear tape to protect the label.

7.7.4 Tape the sample lid (using electrical or clear tape) to prevent leaks.

7.8 Field Documentation

7.8.1 Double-check the collection and recording of the field data each step of the way with the other field team member(s) to ensure accurate documentation. Further, review the work before leaving the site.

ENV007.01 Page 18 of 19

7.8.2 Complete the Well Sampling Log (Attachment C) for each well sampled. The logs will be a permanent part of the field records and will be maintained with the field logbooks.

7.8.3 Document sampling activities in the groundwater field logbook in accordance with E& E’s Field Activity Logbooks7. Reference in the logbook any forms or data sheets used to record field information (e.g., Well Sampling Log, Water Quality Calibration Log). The information on those forms and data sheets does not have to be duplicated in the logbook.

7.8.4 Make corrections to field documentation by drawing a single line through the original entry (so that the original entry can still be read) and writing the corrected entry alongside. Corrections must be initialed and dated.

7.9 Biennial Internal Well Inspection and Total Depth Measurement

Biennial internal well inspection and measurement of total depth will be conducted in conjunction with one of the semiannual sampling rounds.

7.9.1 After sampling is completed at the well, carefully remove the pump and tubing (from wells with bladder pumps) or the bailer (from wells with bailers), and lay it on a piece of clean plastic.

7.9.2 Inspect pumps, pump parts, pump tubing, and bailers for wear, damage, cleanliness, cracking, holes, clogging, worn connections and other integrity problems. Inspect bailer check-ball assemblies for wear and the potential for leakage. Inspect bailer ropes to be sure they are secured well on both ends and are intact. Record the inspection findings in the field logbook.

7.9.3 Measure the total depth of the well to the nearest 0.01 foot using a water level indicator as follows:

7.9.3.1 Measure and record the distance between the sensitive (the conductivity sensor) part of the probe tip and the physical end of the probe tip.

7.9.3.2 Lower the water level probe to the bottom of the well. Feel for the bottom of the well with the probe tip, being sure to remove slack from the measuring tape.

7.9.3.3 Measure the total depth from the north side of the top of the inner casing (TOIC) or other approved reference point.

7.9.3.4 Record the measurement and double-check it. Add to the measurement the distance between the sensitive part of the probe tip and the physical end of the probe tip as measured in Step 7.9.3.1. Compare the new total depth with the previous biennial total depth and the construction total depth as a further check of its accuracy and reasonableness.

7 Ecology and Environment, Inc. (E&E), Field Activity Logbooks, DOC 2.1, Lancaster, New York, 1998.

ENV007.01 Page 19 of 19

7.9.3.5 Decontaminate the water level indicator with analyte-free DI water between wells.

7.9.3.6 Carefully replace the pump or bailer in the well.

7.9.3.7 Close and lock the well.

8.0 RECORD KEEPING

Maintain the following documentation in the project files:

 The original, completed Well Sampling Logs and Water Quality Calibration Log  Groundwater field logbook  Results of biennial well inspections and total depth measurements

9.0 ATTACHMENTS

Attachment A: Figure 1 – Groundwater Sampling Locations (one page)

Attachment B: Water Quality Calibration Log (one page)

Attachment C: Well Sampling Log (one page)

This page intentionally left blank.

ATTACHMENT A

Figure 1 –Groundwater Sampling Locations

This page intentionally left blank.

Figure 1: Groundwater Sampling Locations

ENV007.01 A-1

This page intentionally left blank.

ATTACHMENT B

Water Quality Calibration Log

This page intentionally left blank.

Attachment B

ENV007.01 B-1

This page intentionally left blank.

ATTACHMENT C

Well Sampling Log

This page intentionally left blank.

Attachment C

Central File # 30105-0006

ENV007.01 C-1

This page intentionally left blank

West Valley Site Management Program Page 1 of 5 ENVIRONMENTAL MONITORING PROCEDURE 06/26/2012

TITLE: Field Sample Management ENV008.01

1.0 PURPOSE

This procedure establishes the methods for managing samples collected at the State-Licensed Disposal Area (SDA), including maintaining custody, custody documentation, packaging, and preparation for off-site transport to analytical laboratories.

2.0 SCOPE

This procedure:

 Defines the requirements for maintaining sample custody, preparing chain-of-custody (COC) forms, cross-checking and reconciling samples prior to off-site transport, and packaging and preparing samples for off-site transport to analytical laboratories.

 Does not address sample labeling and field documentation pertaining to sample collection itself (such as sampling logs), which are addressed in individual sampling procedures.

3.0 EQUIPMENT AND SUPPLIES

3.1 Sample Packaging - COC seals, bubble wrap, foam inserts, clear packing tape, strapping tape, mailing/address labels, airbills or bills of lading, shipping coolers.

3.2 Documentation - COC forms, field logbook.

4.0 DEFINITIONS

4.1 State-Licensed Disposal Area (SDA) - a management area consisting of:

 A 15-acre landfill containing radioactive and hazardous wastes in 14 disposal trenches.  Three closed and filled lagoons.  The T-1 building.  The Frac Tank Building, which contains never-used frac tanks and storage facilities for both clean supplies and solid wastes generated from SDA activities (both contaminated and uncontaminated solid wastes). ENV008.01 Page 2 of 5

5.0 HEALTH AND SAFETY

Personnel who perform field sample management must be aware of the potential hazards associated with this work, and will use appropriate precautions and controls to avoid injury or illness. Health and safety requirements and guidance specific to this work are addressed in the individual sampling procedures.

6.0 QUALITY REQUIREMENTS

Sample management shall be conducted in accordance with applicable guidance in the Multi-agency Radiological Laboratory Analytical Protocols Manual (MARLAP), EPA QA/G-8, Guidance on Environmental Data Verification and Data Validation, and EPA QA/R-5, EPA Requirements for Quality Assurance Project Plans. Applicable or pertinent requirements have been integrated into this procedure.

7.0 PROCEDURE

7.1 Sample Custody

A sample is in custody if it is in someone's physical possession, in someone's view, locked up, or otherwise kept in a secured area that is restricted to authorized personnel. The following sample custody procedures will be used to ensure proper control of samples while in the field and during transport to analytical laboratories.

7.1.1 If not already done so, affix signed and dated custody seals over the lids of sample bottles. Place tape around the seals to secure them (electrical tape or clear packing tape work well to secure sample lids and custody seals).

7.1.2 Add any required ice or coolants to coolers of samples required to be maintained at 4° C.

7.1.3 Affix signed and dated custody seals to coolers and boxes of collected samples that are in temporary storage pending sampling completion. Securely tape shut the coolers and boxes of samples, and ensure that the custody seals are covered with the tape so that opening the cooler or box will destroy the integrity of the custody seals.

7.1.4 Store sealed and taped boxes and coolers of samples in a locked or secure area when not in view or possession of the field team.

7.1.5 Affix signed and dated custody seals to boxes of unused sample bottles and secure the boxes with tape. Do not use sample bottles from unsealed boxes or bottles that appear to have been tampered with.

ENV008.01 Page 3 of 5

7.2 Chain-of-Custody Documentation

7.2.1 Complete an appropriate COC form (typically obtained from the analytical laboratory) in duplicate for each shipment of samples to a laboratory. Include the following information at a minimum:

 Name and organization of person collecting the samples,  Sample IDs,  Sample Location IDs,  Date and time samples were collected,  Type of sample (composite/grab),  QC sample type (only indicate MS/MSD or lab replicate volumes; field duplicate samples, field blank samples, and trip blank samples should not be identified as such on the COC - they are supposed to be blind to the lab),  Numbers and types of sample containers per sample,  Preservatives,  Required analyses (including analytical method),  Airbill or bill of lading numbers and transport information,  Signatures for sample relinquishment and receipt, and  Any additional or special handling requirements, such as special instructions, rapid turnaround time requirements, or scope of work changes.

7.2.2 Include the original COC form with the samples sent to the laboratory. Provide a copy of the COC record, airbill, and any other transport documents to the Ecology & Environment project manager.

7.2.3 Before samples are packaged and prepared for transport, cross-check and verify that all recorded sample information on sample labels, COC forms, and sampling logs is accurate and complete. Correct any errors that are found. Make a notation in the field logbook that this cross-check was performed.

7.2.4 Make corrections to COC forms and any other field documentation by drawing a single line through the original entry (so that the original entry can still be read), and writing the corrected entry alongside. Initial and date any corrections.

7.3 Sample Packaging and Transport

Sample packaging and transport will be performed in a manner that protects the sample and complies with applicable regulations in 49 CFR (U.S. Department of Transportation) and, for Federal Express shipments, the International Air Transport Association’s (IATAs) Dangerous Goods Regulations (most recent annual revision). The instructions below assume that the WVSMP environmental monitoring program samples (i.e., groundwater, surface water, and stormwater samples) will be transported as nonhazardous materials, which has been the case in the recent past.

ENV008.01 Page 4 of 5

7.3.1 Ensure that samples are screened for off-site release as required by the facility’s Radiation Protection department. This will likely include the preparation of release forms (e.g., “L” orders, radiological surveys, release tags, etc.), and coordination with facility personnel. Provide a copy of any release tags to the facility or client representative.

7.3.2 After screening is complete, place each sample container in a zipped, plastic bag, and wrap any glass sample container in bubble wrap.

7.3.3 Place bagged sample containers in the shipping container (cooler). Alternate glass containers with poly-containers to further prevent breakage during shipping.

7.3.4 Add ice or coolants to the sample coolers required to be maintained at 4 °C during transport. Ensure that the coolers contain sufficient coolant to maintain the required temperature for the duration of transport. If ice is used, bag it securely in single or double-zipped plastic bags to prevent leakage as it melts.

7.3.5 Use inert packing materials (e.g., cardboard inserts, foam inserts, bubble wrap) as necessary to prevent the containers from moving and hitting each other during transport.

7.3.6 Place the completed COC form in a plastic bag, and tape it to the top inside cover of the shipping container (e.g., the inside of the cooler lid).

7.3.7 Tape shut the fluid drainage valve on the cooler.

7.3.8 Apply at least two signed and dated custody seals to the shipping container. The seals should be fastened with strapping tape that is wrapped fully around the seals and the shipping container.

7.3.9 Affix a mailing label to the cooler with the name and address of the consignor and the receiving laboratory. Cover the mailing label with clear packing tape. Also, affix the completed airbill or bill of lading, using one airbill per cooler. When estimating cooler weights for the airbill, estimate low.

7.3.10 Follow site requirements for leaving samples with the Security office for pickup by routine courier services (such as FedEx), when applicable, or deliver sample packages to the courier service when on-site pickup is not available.

7.4 Field Documentation

7.4.1 Double-check the collection and recording of the field data each step of the way with the other member(s) of the field team to ensure accurate documentation. Further, review the work before leaving the site.

ENV008.01 Page 5 of 5

8.0 RECORD KEEPING

The project files will include the following documentation:

 Field logbook  COC forms  Airbills and/or bills of lading

9.0 REFERENCES AND BIBLIOGRAPHY

9.1 U.S. Environmental Protection Agency (EPA), et al., 2004, Multi-agency Radiological Laboratory Analytical Protocols Manual (MARLAP), Washington, DC.

9.2 ______, 2002, Guidance on Environmental Data Verification and Data Validation, EPA QA/G-8, Washington, DC.

9.3 ______, 2001, EPA Requirements for Quality Assurance Project Plans, EPA QA/R-5, Washington, DC.

This page intentionally left blank. West Valley Site Management Program Page 1 of 11 ENVIRONMENTAL MONITORING PROCEDURE 01/04/2012

TITLE: Assessment and Reporting of SDA Data ENV009.01

1.0 PURPOSE

This procedure establishes the methods for assessing and reporting data collected from the State-Licensed Disposal (SDA) area (e.g., analytical data, water elevations and environmental TLD results).

2.0 SCOPE

This procedure defines the methods and requirements for:

 Assembling and reviewing the information needed to produce the routine data reports.  Performing and reporting routine and annual statistical assessments of SDA data.  Comparing results with regulatory standards and historical results.  Notifying NYSERDA if statistical or comparison thresholds have been exceeded.  Reporting SDA data in hard-copy tables and electronic files compatible for import to NYSIMSII.

Formal assessment and reporting of SDA data will be performed using validated data. This procedure does not address data review and validation itself, which are addressed in procedures ENV010, Verification and Validation of Radioanalytical Data, and ENV011, Verification and Validation of Chemical Analytical Data.

3.0 EQUIPMENT AND SUPPLIES

3.1 SPSS and/or Statistica statistical software program, Excel and Access

3.2 Water Elevation Database

3.3 Control Charting for Non-Groundwater SDA Media (a statistical control-charting program)

3.4 Copy of the NYSIMSII database

3.5 DUMPStat (commercial statistical code)

4.0 QUALITY REQUIREMENTS

4.1 At a minimum, manual manipulation and handling of data will be double-checked by the person handling the data. For example, data that is hand-entered into a database or spreadsheet will be double-checked to ensure that it was entered accurately; a column of results that is added will be added twice; and so on.

ENV009.01 Page 2 of 11

4.2 Data will be double-checked and cross-checked at each handling and transfer step. An example of cross-checking is ensuring that a reporting table that is auto-generated out of NYSIMSII, for example, contains the same information as the input file used to create the table.

4.3 Outliers identified as a result of the statistical tests performed as part of this procedure will be excluded from data sets only after investigation confirms that an error has been made in data collection, measurement, or analysis, or that the data point does not belong to the population for other known reasons. Otherwise, outliers without known cause will be included in the data set.

4.4 In general, data will be used and reported in the same form and with the same number of significant figures as originally reported by analytical laboratories or the environmental TLD vendor. As well, results will be calculated, reduced, and reported using the correct number of significant figures.

5.0 PROCEDURE

5.1 Reporting: Groundwater (1100-Series Monitoring Well) Sampling

5.1.1 Review of Field and Analytical Documentation

5.1.1.1 As soon as practicable after the semiannual sampling effort, review the Well Sampling Logs, chains-of-custody, field logbook, and other information for accuracy and completeness (see ENV007, Groundwater Sampling).

5.1.1.2 Assemble the validated analytical data packages for the groundwater constituents (typically one each for chemical and radioanalytical data).

5.1.1.3 Assign any data qualifiers to the field water quality results as a result of data review (e.g., sometimes the field water quality results might be qualified due to performance problems with the water quality measuring instruments).

5.1.2 Assembly of Electronic Analytical and Field Water Quality Data

5.1.2.1 Review the electronic data deliverables (EDDs) provided by the analytical laboratories (chemical lab and radioanalytical lab). Ensure that they match the validated hard-copy results and correct any discrepancies.

5.1.2.2 Assemble the approved electronic results from each laboratory in an Excel, Access, or equivalent input file suitable for import to NYSIMSII. Ensure that all of the required data fields have been filled in with accurate information. The electronic files also can be used as the input file for any statistical assessments that are required to be performed.

5.1.2.3 Develop an electronic file for the field water quality results (pH, conductivity, temperature, and turbidity) by hand-entering them into an Excel, Access, or equivalent file suitable for import to ENV009.01 Page 3 of 11

NYSIMSII. Ensure that all of the required data fields have been filled in with accurate information.

5.1.2.4 Import the electronic files (one each from the chemical lab, radioanalytical lab, and field water quality results) into NYSIMSII. Use NYSIMSII or other developed reporting modules to produce report-quality tables of analytical results (an example of another reporting module is an Excel- and Access-based routine used to cross-tab the radiological results into a suitable table of results).

5.1.3 Statistical Assessment of Gross Alpha, Gross Beta and Tritium Results Using a Tolerance/Prediction Interval Protocol

5.1.3.1 Statistically assess the semiannual gross alpha, gross beta and tritium results using the tolerance/prediction interval protocol found in Attachment A (which also is summarized in the Groundwater Monitoring Plan for the State-Licensed Disposal Area (SDA) at West Valley, ENV502) (GMP).

5.1.3.2 Notify NYSERDA immediately of any results that exceed a tolerance limit per Attachment A.

5.1.3.3 Report the statistical results in the semiannual data report for the groundwater samples.

5.1.4 Statistical Assessment of Other Radioanalytical Results by Control Charting

5.1.4.1 Statistically assess the annual gamma emitter, carbon-14, iodine-129, strontium-90, and technetium-99 results using the control charting protocol in Attachment B (which also is summarized in the GMP).

5.1.4.2 Notify NYSERDA immediately of any results that meet the notification criteria in Attachment B.

5.1.4.3 Report the statistical results in the semiannual data report for the groundwater samples.

5.1.5 Comparison of Volatile Organic Compounds (VOC) Results to Regulatory Standards and Practical Quantitation Limits

5.1.5.1 Compare validated VOC results to groundwater quality standards and guidance (e.g., Classifications and Standards of Quality and Purity, 6 NYCRR 700 to 705) and supplementary guidance in NYSDEC Ambient Water Quality Standards and Guidance Values and Groundwater Effluent Limitations, TOGS 1.1.1.

5.1.5.2 Notify NYSERDA immediately of any results meeting the following conditions:

 A validated VOC concentration in a well exceeds the groundwater quality standard or guidance ENV009.01 Page 4 of 11

value;  An estimated VOC concentration exceeds the groundwater quality standard or guidance value; or  A validated VOC concentration exceeds the PQL, for a compound not listed in groundwater quality standards or guidance.

Also assess such results for trends.

5.1.5.3 Report the results in the semiannual data report for the groundwater samples.

5.1.6 Development of Semiannual Groundwater (1100-Series Monitoring Well) Data Report

6.1.6.1 Develop the semiannual groundwater (1100-series monitoring well) data report to include:

 A description of the work performed  Tables of validated chemical and radioanalytical results  A table of field water quality results  A discussion of significant results  An overall comparison of results with historical data  Results of statistical tests and regulatory comparisons  An assessment of data QA/QC and usability (also see Attachment F)  Any applicable corrective actions  Program inspection and maintenance activities

5.1.6.2 Assemble a NYSIMSII-compatible EDD for the semiannual chemical, radioanalytical, and field water quality data for NYSERDA to import to NYSIMSII.

5.2 Reporting: Groundwater and Leachate Elevation Measurement

5.2.1 Review of Field Documentation

5.2.1.1 As soon as practicable after the quarterly measurements are obtained, review the Water Elevation Field Record, the Trench Leachate Elevation Data Field Measurements Worksheet, field logbook, and other information for accuracy and completeness. (See ENV006, Groundwater Elevation Measurements, and ENV004, Trench Leachate Elevation Monitoring Procedure for the West Valley Site Management Program.)

5.2.1.2 Provide the completed Trench Leachate Elevation Data Field Measurements Worksheet to NYSERDA no later than the day following the measurements.

5.2.2 Assembly of Electronic Water Elevation Data

5.2.2.1 Review the Water Elevation Database Access-based reporting module to ensure it is populated with ENV009.01 Page 5 of 11

the most recent, accurate survey reference elevations for the 49 groundwater and 13 trench leachate locations. The water elevation database is used to calculate the water elevations, assemble the hard-copy reporting table and develop an EDD (.dbf file) for submittal to NYSERDA.

5.2.2.2 Enter the field-measured outages (i.e., the distance from the survey reference point on the casing to water) for the 49 groundwater elevation locations (21 1100-series wells, 18 piezometers, 9 slit-trench wells, and boring B-14) into the water elevation database. Ensure that all of the required data fields have been filled in with accurate information.

5.2.2.3 Do the same for the field-measured outages for the 13 leachate elevation locations. The water elevation database assembles a separate hard-copy reporting table and EDD for the leachate elevations. Ensure that all of the required data fields have been filled in with accurate information.

5.2.3 Development of Quarterly Groundwater Contour Maps

5.2.3.1 Use the quarterly groundwater and leachate elevations to develop the groundwater contour maps for the Weathered Lavery Till and Kent Recessional geological units.

5.2.3.2 Have the maps digitized into a computer-aided drafting (CAD) file (.dwg).

5.2.3.3 Ensure that the two quarterly contour maps are accurate and consistent with the technical specifications of previous quarterly contour maps.

5.2.4 Development of a Quarterly Water Elevation Report

5.2.4.1 Develop the quarterly water elevation report to include:

 A description of the work performed  Tables of groundwater and leachate elevations  Hard-copy groundwater contour maps for the Weathered Lavery Till and Kent Recessional units  A discussion of significant results  A list of any new high groundwater elevations  An overall comparison of results with historical data  Results of regulatory comparisons (e.g., leachate elevations that exceed reporting triggers in ENV501, Leachate Monitoring Plan for the State-licensed Disposal Area (SDA) at West Valley)  An assessment of data QA/QC and usability (also see Attachment F)  Any applicable corrective actions  Program inspection and maintenance activities

5.2.4.2 Assemble the electronic .dbf files produced by the water elevation database (one file each for the groundwater and leachate elevations) for NYSERDA to import to NYSIMSII. Convert the CAD files (.dwg) of the groundwater contour maps to Windows metafiles (.wmf) and submit to ENV009.01 Page 6 of 11

NYSERDA.

5.2.5 Annual Statistical Assessment of Groundwater and Leachate Elevations

5.2.5.1 Statistically assess the annual water elevations with respect to historical data using the statistical protocol in Attachment D.

5.2.5.2 Develop the annual water elevation statistical assessment report to include:

 A description of the work performed  Excel time plots for 62 water elevation locations  Graphs and tables of DUMPStat statistical results  A discussion of significant results  An overall comparison of results with previous statistical assessments

5.3 Reporting: Surface Water Sampling

5.3.1 Review of Field and Analytical Documentation

5.3.1.1 As soon as practicable after the quarterly sampling effort, review the Surface Water Sampling Logs, chains-of-custody, field logbook, and other information for accuracy and completeness (see EMP-3, Surface Water Sampling).

5.3.1.2 Assemble the validated analytical data package for the surface water constituents (one package for radioanalytical data).

5.3.2 Assembly of Electronic Analytical Data

5.3.2.1 Review the EDD provided by the radioanalytical laboratory. Ensure that it matches the validated hard-copy results and correct any discrepancies.

5.3.2.2 Assemble the approved electronic results in an Excel, Access, or equivalent input file suitable for import to NYSIMSII. Ensure that all of the required data fields have been filled in with accurate information. The electronic file also can be used as the input file for the statistical assessment.

5.3.2.3 Import the electronic file into NYSIMSII. Use NYSIMSII or other developed reporting modules to produce a report-quality table of the analytical results as possible (an example of another reporting module is an Excel- and Access-based routine used to cross-tab the radiological results into a suitable table of results).

5.3.3 Statistical Assessment of Radioanalytical Results by Control Charting

5.3.3.1 Statistically assess the quarterly gross alpha, gross beta, and tritium results using the control ENV009.01 Page 7 of 11

charting protocol in Attachment C.

5.3.3.2 Report the statistical results in the quarterly data report for the surface water samples.

5.3.4 Development of a Quarterly Surface Water Data Report

5.3.4.1 Develop the quarterly surface water data report to include:

 A description of the work performed  A table of validated radioanalytical results  A discussion of significant results  An overall comparison of results with historical data  Results of statistical tests and regulatory comparisons  An assessment of data QA/QC and usability (also see Attachment F)  Any applicable corrective actions  Program inspection and maintenance activities

5.3.4.2 Assemble a NYSIMSII-compatible EDD for the quarterly radioanalytical data for NYSERDA to import to NYSIMSII.

5.3.5 Annual Statistical Assessment of Radioanalytical Results

5.3.5.1 Statistically assess the annual surface water radioanalytical results with respect to historical data using the statistical protocol in Attachment E.

5.3.5.2 Develop the annual surface water statistical assessment report to include:

 A description of the work performed  Graphs and tables of statistical results  A discussion of significant results  An overall comparison of results with previous statistical assessments

5.4 Reporting: Stormwater Sampling

5.4.1 Review of Field and Analytical Documentation

5.4.1.1 As soon as practicable after the semiannual sampling effort, review the Stormwater Sampling Logs, chains-of-custody, field logbook, and other information for accuracy and completeness (see EMP-4, Stormwater Sampling).

5.4.1.2 Assemble the validated analytical data packages for the stormwater constituents (typically one each ENV009.01 Page 8 of 11

for the chemical and radioanalytical data).

5.4.1.3 Assign any data qualifiers to the field water quality results as a result of data review (e.g., sometimes the field water quality results might be qualified due to performance problems with the water quality measuring instruments).

5.4.2 Assembly of Electronic Analytical Data

5.4.2.1 Review the EDDs provided by the analytical laboratories (chemical lab and radioanalytical lab). Ensure that they match the validated hard-copy results and correct any discrepancies.

5.4.2.2 Assemble the approved electronic results from each laboratory in an Excel, Access, or equivalent input file suitable for import to NYSIMSII. Ensure that all of the required data fields have been filled in with accurate information. The electronic files also can be used as the input file for the statistical assessment.

5.4.2.3 Develop an electronic file for the field water quality results (pH and temperature) by hand-entering them into an Excel, Access, or equivalent file suitable for import to NYSIMSII. Ensure that all of the required data fields have been filled in with accurate information.

5.4.2.4 Import the electronic files (one each from the chemical lab, radioanalytical lab, and field water quality results) into NYSIMSII. Use NYSIMSII or other developed reporting modules to produce report-quality tables of analytical results (an example of another reporting module is an Excel- and Access-based routine used to cross-tab the radiological results into a suitable table of results).

5.4.3 Statistical Assessment of Results by Control Charting

5.4.3.1 Statistically assess the semiannual results using the control charting protocol in Attachment C.

5.4.3.2 Report the statistical results in the semiannual data report for the stormwater samples.

5.4.4 Development of Semiannual Stormwater Data Report

5.4.4.1 Develop the semiannual stormwater data report to include:

 Any applicable corrective actions  Program inspection and maintenance activities

5.4.4.2 Assemble a NYSIMSII-compatible EDD for the semiannual chemical, radioanalytical, and field water quality data for NYSERDA to import to NYSIMSII.

5.4.5 Annual Statistical Assessment of Results

5.4.5.1 Statistically assess the annual stormwater results with respect to historical data using the statistical protocol in Attachment E.

5.4.5.2 Develop the annual stormwater statistical assessment report to include:

 A description of the work performed  Graphs and tables of statistical results  A discussion of significant results  An overall comparison of results with previous statistical assessments

5.5 Reporting: Environmental TLD Monitoring

5.5.1 Review of Field and Analytical Documentation

5.5.1.1 As soon as possible after the quarterly field exchange of the TLDs, review the SDA Environmental TLD Deployment/Retrieval Form, field logbook, and other information for accuracy and completeness (see EMP-5, Environmental TLD Monitoring).

5.5.1.2 Assemble the validated data package for the environmental TLD data. Ensure that the field TLD results have been adjusted by the transit and storage exposures.

5.5.2 Assembly of Electronic Environmental TLD Data

5.5.2.1 Develop an electronic file for the environmental TLD results by hand-entering the calculated (data-reduced) values into an Excel, Access, or equivalent file suitable for import to NYSIMSII. Ensure that all of the required data fields have been filled in with accurate information. The electronic file also can be used as the input file for the statistical assessment.

5.5.2.2 Import the electronic file into NYSIMSII. Use NYSIMSII or other developed reporting modules to produce report-quality tables of analytical results (an example of another reporting module is an Excel- and Access-based routine used to cross-tab the radiological results into a suitable table of results). ENV009.01 Page 10 of 11

5.5.3 Statistical Assessment of Results by Control Charting

5.5.3.1 Statistically assess the quarterly TLD results using the control charting protocol in Attachment C.

5.5.3.2 Report the statistical results in the quarterly data report for the environmental TLD monitoring.

5.5.4 Development of a Quarterly Environmental TLD Data Report

5.5.4.1 Develop the quarterly environmental TLD data report to include:

 A description of the work performed  A table of validated results  A discussion of significant results  An overall comparison of results with historical data  Results of statistical tests  An assessment of data QA/QC and usability (also see Attachment F)  Any applicable corrective actions  Program inspection and maintenance activities

5.5.4.2 Assemble a NYSIMSII-compatible EDD for the quarterly environmental TLD data for NYSERDA to import to NYSIMSII.

5.5.5 Annual Statistical Assessment of Results

5.5.5.1 Statistically assess the annual environmental TLD results with respect to historical data using the statistical protocol in Attachment E.

5.5.5.2 Develop the annual environmental TLD statistical assessment report to include:

 A description of the work performed  Graphs and tables of statistical results  A discussion of significant results  An overall comparison of results with previous statistical assessments

6.0 RECORDKEEPING

The project files will include the following documentation:

 Electronic copies of input data files used for statistical assessments  Records of adjustments made to SDA data for the purpose of statistical assessments  Records of tests performed on data sets to evaluate distribution, data characteristics and outliers  Records of the rationale and process used to select historical data sets ENV009.01 Page 11 of 11

 Records of the algorithms, codes, programming, and/or settings used to develop and implement statistical routines and/or operate statistical software programs  Both hard and electronic copies of reports provided to NYSERDA related to data assessment and reporting  The contractor’s copy of NYSIMSII database  A copy of each final EDD provided to NYSERDA

7.0 REFERENCES AND BIBLIOGRAPHY

7.1 Discerning Systems, Inc., 2000, DUMPStat Statistical Groundwater Monitoring Software, Burnaby, BC, Canada.

7.2 Ecology and Environment, Inc. (E&E), 2000, Work Plan and Sampling and Analysis Plan (SAP) for the State-Licensed Disposal Area (SDA) Groundwater Monitoring Program, Lancaster, New York.

7.3 New York State Energy Research and Development Authority (NYSERDA), Groundwater Monitoring Plan for the State-Licensed Disposal Area (SDA) at West Valley, ENV502, West Valley, NY.

7.4 U.S. Environmental Protection Agency (EPA), et al., 2004, Multi-agency Radiological Laboratory Analytical Protocols Manual (MARLAP), Washington, DC.

7.5 ______, 2001, EPA Requirements for Quality Assurance Project Plans, EPA QA/R-5, Washington, DC.

8.0 ATTACHMENTS

Attachment A: Tolerance/Prediction Interval Protocol for Groundwater Tritium, Gross Alpha, and Gross Beta Data (four pages)

Attachment B: Control Chart Protocol for Other Groundwater Radiological Constituents (two pages)

Attachment C: Control Chart Protocol for Other SDA Environmental Media Constituents (two pages)

Attachment D: Annual Statistical Assessment of Groundwater and Leachate Elevations (two pages)

Attachment E: Annual Statistical of Other SDA Environmental Media and Constituents (one page)

Attachment F: Data Quality Indicators to be Assessed During Reporting (three pages)

This page intentionally left blank.

ATTACHMENT A

Tolerance/Prediction Interval Protocol for Groundwater Tritium, Gross Alpha, and Gross Beta Data

This page intentionally left blank. Attachment A

Tolerance/Prediction Interval Protocol for Groundwater Tritium, Gross Alpha, and Gross Beta Data

1. Overview The semiannual tritium, gross alpha, and gross beta groundwater data will be statistically assessed for significant changes using a two-phase tolerance and prediction interval testing strategy. The approach employs both upper tolerance limits (UTLs) and upper prediction limits (UPLs)—the upper bounds for a tolerance interval and prediction interval, respectively. These limits will be calculated for each constituent in each well using historical data. UTLs will be calculated with prespecified coverage and confidence goals. In some cases, a nonparametric UPL will be used initially instead of a UTL.

Validated results for each well will be compared to their respective UTLs (or nonparametric UPLs). Tritium results will be additionally compared to a programmatic secondary concentration limit (SCL) of 6.00E-07 μCi/ml. Exceedances will be investigated by NYSERDA and NYSDEC, who will determine further actions, such as resampling and comparison to a UPL, as described later in this attachment.

2. Background Regarding the Test The tolerance/prediction interval test is described in some detail in E&E 2000. The two-phased approach balances high statistical power (in this case, the ability to detect real releases), which is maintained for the test by the use of tolerance limits, with high confidence level, which is achieved by resampling and retesting with prediction limits. In the basic approach, there is an initial application of tolerance intervals to the data. Resampling is then performed for those constituents that exceed their tolerance limits, and the results of the resampling are compared to a prediction interval. If the constituent passes the prediction interval test, then its detection in the first phase is assumed to be a false positive and routine monitoring continues. If the constituent fails the prediction interval test, it is considered to have been detected at a level significantly higher than previously observed concentrations. This would constitute a "detect" in the program and trigger further action (e.g., resampling followed by comprehensive analysis).

Tolerance intervals are designed to permit a small number of statistical failures (false positives) and prediction limits are designed to permit none. Thus, tolerance intervals tend to be smaller than prediction intervals at a given level of confidence. As a practical matter, this means that the tolerance interval is more likely to detect a real release than is the prediction interval.

3. Application of the Protocol

Development of UTLs The flowchart in Figure 1-1 illustrates the steps involved in developing the UTLs for the tritium, gross alpha, and gross beta data for each of the 1100-series wells. For each well and parameter, the historical data will first be assembled, reviewed and edited. Then each value in the historical data set will be assigned the status of either “detect” or “nondetect” depending on the way the value was reported in the historical data. The percentage of detects in the data set will then be determined as a preliminary step in moving the process toward parametric or nonparametric testing.

ENV009.01 A-1 Attachment A

Figure 1-1: Development of UTLs

ENV009.01 A-2 Attachment A

If there are greater than 50% detects in the historical data, then adjustments for nondetects will be made following EPA guidance. These adjustments will depend on the data, any qualifiers associated with the data, and other factors and will typically result in assigning a functional value to nondetects so they may be included in statistical calculations.

The unadjusted and adjusted data distributions will be tested for normality, lognormality, and other statistical qualities (e.g., skew, standard deviation), per E&E 2000. If the historical data for a constituent (with more than 50% detects) are normally or lognormally distributed, than a parametric UTL will be calculated for each of these wells and constituents. If the historical data for a constituent with more than 50% detects are not normally or lognormally distributed, or if there are fewer than 50% detects, then a nonparametric UPL will be determined. The nonparametric UPL will be set equal to the maximum observed historical value for the data. In cases where all of the historical detects are below the sample detection limits, the nonparametric UPL would be set equal to the detection limit. The broad use of nonparametric UPLs followed by verification resampling is considered to be a viable statistical assessment approach for many data sets characterized by a very low percentage of detects or other distribution problems, or when UTLs with appropriate confidence and coverage cannot be achieved.

Statistical Data Assessment The flow chart in Figure 1-2 illustrates the steps involved in comparing each new tritium, gross alpha, and gross beta result with its well-specific UTL (or UPL).

The semiannual tritium, gross alpha, and gross beta results for each well will be compared to their respective UTLs (or nonparametric UPLs). If the result does not exceed its UTL (or nonparametric UPL), then routine monitoring of the well for that parameter will continue. If a tritium result exceeds its UTL (or nonparametric UPL), then the result will be compared to the tritium SCL (6.00E-07 μCi/ml), which was derived from a range of industry-standard tritium detection limits. If a tritium result exceeds both its UTL (or nonparametric UPL) and the SCL, or if a gross alpha or gross beta result exceeds its UTL (or nonparametric UPL), then NYSERDA will consult with NYSDEC regarding resampling of the well for the exceeding parameter.

During the consultation with NYSDEC, NYSERDA will provide information on the results of the statistical assessment, results of any comparisons with SCLs, and the historical data for the parameter and well in question. If the decision is made not to resample, then routine monitoring of the well for the exceeding parameter will continue. If the decision is made to resample, then a new, independent sample will be collected from the well and analyzed for the constituent in question. The new result will then be compared to the corresponding calculated UPL (or, when a nonparametric UPL was initially assigned, will be compared again to the initial nonparametric UPL). UPLs will be calculated or assigned from the historical data in accordance with the guidance. If the new result does not exceed its UPL, routine monitoring of the well for that parameter will continue. If the new result exceeds the UPL, the constituent will be considered to have been detected at a level significantly higher than the well’s historical concentration. NYSERDA will notify NYSDEC at this point in accordance with the GMP.

Evaluation of the Protocol The tolerance/prediction limit protocol should be reviewed and evaluated periodically after implementation to assess its performance and determine whether and when the UTLs and UPLs should be updated.

ENV009.01 A-3 Attachment A

Figure 1-2: Statistical Data Assessment for Tritium, Gross Alpha, and Gross Beta

ENV009.01 A-4

ATTACHMENT B

Control Chart Protocol for Other Groundwater Radiological Constituents

This page intentionally left blank.

Attachment B

Control Chart Protocol for Other Groundwater Radiological Constituents

1. Overview The annual results for the groundwater gamma scan, C-14, I-129, Sr-90, and Tc-99 parameters will be statistically assessed for significant changes using a control chart methodology that is prescribed by the GMP. A control chart will be developed for a well and parameter when the historical data contain a minimum of five positive detections for the parameter. Validated results will be compared to the control limits. Results meeting particular control charting criteria will be investigated by NYSERDA and NYSDEC, who will determine further actions.

2. Background Regarding the Test A control chart is a graphical tool used to monitor a process or system for both normal and unusual variation. It commonly consists of an average value and upper and lower control limits calculated from a historical body of data. New results that fall outside of the limits are considered to be statistically different from the historical data. The number and placement of such out-of-control results are assessed to help describe and understand the variation.

3. Application of the Protocol

Development of Control Charts The annual gamma scan, C-14, I-129, Sr-90, and Tc-99 data will be assessed for each well to determine if a control chart should be developed. A control chart will be developed for a well and parameter when the historical data contain a minimum of five positive detections for the parameter. An analytical result will be considered a positive detection when it meets all of the following criteria:

 It is greater than zero;

 It is greater than the achieved detection limit for the analysis;

 It is greater than its analytical uncertainty; and

 It is not qualified.

Before the mean and control limits are calculated for the chart, a statistical program (such as SPSS, Statistica, Excel, or an equivalent) will be used to test the data for that parameter and location for characteristics such as normality, distribution, and trend in order to understand the population that will be used to construct the control chart limits. Unusual distributions, statistical outliers, and/or trending data will be evaluated to determine whether the data set is suitable for constructing control chart limits.

Outliers can be assessed using Dixon’s Test or an appropriate equivalent (an appropriate outlier test will be selected based on qualities such as the normality, quantity and distribution of the data). Statistical outliers will be evaluated to determine whether they are due to a known process cause or are inexplicable, and whether they should be removed from the historical data set before constructing the control chart.

ENV009.01 B-1 Attachment B

NYSERDA will be notified of data sets that meet the basic requirements for control charting (i.e., five positive detections as defined above) but are deemed not suitable for constructing control chart limits for reasons such as poor fit, unacceptable trending, outliers, or a distribution that indicates that the data are not comparable to each other or representative of the conditions at that environmental location.

Once at least five quality, positive detections have been assembled, the control chart will be constructed using a program that will display the chart, control limits, and data points (e.g., Excel works well). The mean and standard deviation (SD) will be calculated for the data. The mean and four control limits (mean + 2 SD, mean - 2 SD, mean + 3 SD, and mean - 3 SD) will be entered as horizontal lines on the chart. The five data points used to calculate the mean and control limits also should be plotted on the chart.

Statistical Data Assessment New, validated, positive detection results (past the initial five positive detections) will be added to the chart and compared to the control limits. NYSERDA will notify NYSDEC of any validated, positive result meeting any of the following four criteria:

 The result exceeds the mean plus three standard deviations;

 The result is the third consecutive result exceeding the mean plus two standard deviations;

 The result is the seventh consecutive positive result falling above the mean; or

 The result is the fifth in a series exhibiting a successive increase.

If a qualifier is assigned to an analytical result that would otherwise have exceeded the first notification criterion or would have continued along a path toward exceeding any of the other notification criteria, NYSERDA will discuss the situation with its environmental monitoring program contractor and NYSDEC.

Updating Control Charts Each control chart will be periodically evaluated to determine when it is time to update the chart by changing the range of historical data used, recalculating control limits to include newer data and/or exclude older data, etc. For annual parameters such as those discussed herein, a control chart should be re-evaluated once whenever at least four to six new, positive detection results are obtained. The new data points will be statistically evaluated to determine whether they are representative of the historical data set, after which decisions will be made regarding which of the existing data should be used to construct the updated control chart.

ENV009.01 B-2

ATTACHMENT C

Control Chart Protocol for Other SDA Environmental Media and Constituents

This page intentionally left blank.

Attachment C

Control Chart Protocol for Other SDA Environmental Media and Constituents

1. Overview The routine results for nongroundwater media (such as the quarterly surface water radiological data, semiannual stormwater data, and quarterly environmental TLD data) will be statistically assessed for significant changes using a control chart methodology. Results meeting particular control charting criteria will be investigated by NYSERDA, who will determine further actions.

2. Background Regarding the Test A control chart is a graphical tool used to monitor a process or system for both normal and unusual variation. It commonly consists of an average value, and upper and lower control limits calculated from a historical body of data. New results that fall outside of the limits are considered to be statistically different from the historical data. The number and placement of such out-of-control results are assessed to help describe and understand the variation.

3. Application of the Protocol

Development of Control Charts A control chart will be developed for the results for each new round of surface water, stormwater, and environmental TLD monitoring, for each location and parameter, using the Access-based program Control Charting for Non-Groundwater SDA Media. The program functions in accordance with the following general criteria:

1. Unless otherwise noted, the data set used for each parameter and location consists of data from 1/1/91 to the present. 2. The data set for each parameter and location are first reviewed to determine statistical characteristics such as normality, skewness, and outliers. Unusual characteristics are evaluated and discussed with NYSERDA. Outliers with assignable causes are typically removed from the data set. 3. Known sample replicates and duplicates are averaged together prior to calculation of the grand mean and grand uncertainty for each parameter and location. 4. Instances of "0.00E+00±uncertainty" in the historical data set, which represent "less than" values, are left as zeroes for the purposes of calculating the mean, and are not replaced with a functional value. 5. The new quarterly mean and standard deviation are calculated in exclusion of any R-qualified results and in exclusion of the most recent seven usable (i.e., non-R-qualified) results. The mean is calculated for all data in the historical data set regardless of collection frequency; therefore, the mean might not be evenly weighted according to sampling frequency. At least five independent data points are required to calculate the mean. 6. If the mean is smaller than the average uncertainty, the standard deviation is assigned to be one-half of the average uncertainty for the purposes of calculating warning and alarm limits. If the mean is larger than the average uncertainty, a typical standard deviation is used in the calculation of the limits. 7. The mean and standard deviation are used to calculate (for each parameter and location): upper alarm limit = mean + 3 assigned standard deviations; upper warning limit = mean + 2 assigned standard deviations.

ENV009.01 C-1 Attachment C

8. Detection limits are not available for the historical data prior to 2/9/06. 9. See additional supporting documentation in project files regarding the setup of this control charting protocol.

Statistical Data Assessment The routine statistical assessment (e.g., quarterly or semiannual) will be conducted in accordance with the following general criteria:

1. The Statistical Result and Identified Trend are evaluated in accordance with the key below. They are evaluated for the most recent seven usable (i.e., non-R-qualified) results, and reported for non-R-qualified and non-U-qualified results. Statistical Results and Identified Trends for displayed historical values prior to 2/9/06 are deduced from available historical information and not reported in the results table if a U-qualified result breaks the trend prior to 2/9/06. 2. Known sample replicates and duplicates among the most recent seven usable results are averaged together for display as a single entry in the results table for use in statistical comparisons. All qualifier flags associated with the averaged result are displayed and are separated by commas if the flags come from separate results.

Statistical Result and Identified Trend Key:

Statistical Result Identified Trend 3 = Non-U-qualified result above upper alarm limit. Any number "3." 2 = Non-U-qualified result above upper warning limit. Any three "2s" in a row. M = Non-U-qualified result above the mean. Any seven "Ms" in a row. B = Non-U-qualified result below the mean. Any seven "Bs" in a row. I = Non-U-qualified result exhibiting an increase over previous result. Any five "Is" in a row. D = Non-U-qualified result exhibiting a decrease from previous result. Any five "Ds" in a row.

Note: Upper alarm limit = mean + 3 assigned standard deviations. Upper warning limit = mean + 2 assigned standard deviations.

Updating Control Charts Each control chart will be periodically evaluated to determine when it is time to update the chart by changing the range of historical data used, calculating control limits using different ranges of data (e.g., to include newer data and/or exclude older data), etc.

ENV009.01 C-2

ATTACHMENT D

Annual Statistical Assessment of Groundwater and Leachate Elevations

This page intentionally left blank.

Attachment D

Annual Statistical Assessment of Groundwater and Leachate Elevations

1. Overview The water elevations for the 49 groundwater locations and 13 trench leachate locations will be statistically assessed on an annual basis for significant changes using trend testing and control charting. Significant statistical results will be investigated by NYSERDA, who will determine further actions.

2. Background Regarding the Tests Trend testing is used to detect significant changes over time in a population of data. Control charts are used to monitor a process or system for variation by comparing new results with control limits that are established from previous data.

3. Application of the Protocol The tests will be performed using DUMPStat, a commercial statistics code written to assess groundwater data. DUMPStat will be used to test the elevation data for trend using Sen’s test and for statistically significant changes (with respect to historical data) using combined Shewhart-CUSUM control charts.

The annual water elevation statistical assessment will be performed generally as follows:

1. Assemble the historical and new annual data that will be used to statistically assess the SDA water elevations for the 49 groundwater locations and 13 trench leachate locations. 2. Develop an Excel time plot of water elevation versus time for each of the 62 water elevation locations. Review the time plots for accuracy and completeness. 3. Use SPSS, Statistica, Excel, or an equivalent program to test the water elevation data for each location for characteristics such as normality, distribution, trend, and outliers in order to understand the population that will be subjected to statistical testing using the DUMPStat code (DUMPStat might perform some of these tests itself once the data are imported into it). Evaluate unusual distributions and trending data to determine whether each data set is suitable for running the DUMPStat tests. Remove appropriate outliers (e.g., data points that are statistically different from the population for unknown reasons). 4. Notify NYSERDA of data sets that are not suitable for running the tests for reasons such as poor fit, unacceptable trending, or a distribution that indicates that the data are not comparable to each other or representative of the conditions at that environmental location. 5. Because the DUMPStat graphing routine scales the constituent (in this case, water elevation above mean sea level) y axis to zero, off-set the elevation for each constituent by a number of feet that will result in a reasonably sized plot on the DUMPStat graphs. Use a consistent offset by type of monitoring well. For example, recent offsets have been 1,250 feet for the 1100 “C” wells and 1,350 feet for most of the remaining locations. 6. Run the DUMPStat Sen’s trend test routine for each data set (or for groups of like data sets such as all trenches, or all shallow wells). Choose an appropriate “background” or historical data set (DUMPStat calls it the background data set) in coordination with NYSERDA. The background data set should be reevaluated every two years or so (i.e., with each eight new data points).

ENV009.01 D-1 Attachment D

7. Run the DUMPStat Shewhart-CUSUM control charting routine for each data set (or for groups of like data sets such as all trenches, or all shallow wells). Choose an appropriate “background” or historical data set in coordination with NYSERDA. The background data set should be reevaluated every two years or so (i.e., with each eight new data points). Select other input parameters in accordance with the DUMPStat operating manual and previous annual statistical assessments. 8. Assemble the DUMPStat output, evaluate it and ensure that it is complete and accurate.

ENV009.01 D-2

ATTACHMENT E

Annual Statistical Assessment of Other SDA Environmental Media and Constituents

This page intentionally left blank.

Attachment E

Annual Statistical Assessment of Other SDA Environmental Media and Constituents

1. Overview The results for nongroundwater media (such as the quarterly surface water radiological data, semiannual stormwater data, and quarterly environmental TLD data) collected from on-site locations will be statistically assessed on an annual basis (for each parameter and location) with respect to the results for the background location. Significant statistical results will be investigated by NYSERDA, who will determine further actions.

2. Background Regarding the Test Tests of significance will be performed using appropriate nonparametric or parametric significance tests such as the Mann-Whitney U test, “t” tests or analyses of variance.

3. Application of the Protocol The tests will be performed using SPSS or other statistics codes or programs that run standard significance tests. The annual statistical assessment for nongroundwater media will be performed generally as follows:

1. Assemble the historical and new annual data that will be used for the statistical assessment. 2. Use SPSS, Statistica, Excel, or an equivalent program to test the data for each parameter and location for characteristics such as normality, distribution, trend, and outliers in order to understand the population that will be subjected to statistical testing. Evaluate unusual distributions and trending data to determine whether each data set is suitable for running the statistical tests. Remove appropriate outliers (e.g., data points that are statistically different from the population for unknown reasons). 3. Notify NYSERDA of data sets that are not suitable for running the tests for reasons such as poor fit, unacceptable trending, or a distribution that indicates that the data are not comparable to each other or representative of the conditions at that environmental location. 4. Use the significance test to statistically compare the on-site data for each parameter to the background data for that parameter for the calendar year as follows:  Assess the difference between the results for a given parameter at all on-site locations and the results for that parameter at the background location.  Assess the difference between the results for a given parameter at each on-site location and the results for that parameter at the background location. 5. Assemble the output and results, evaluate it, and ensure that it is complete and accurate.

ENV009.01 E-1

This page intentionally left blank.

ATTACHMENT F

Data Quality Indicators to be Assessed During Reporting

This page intentionally left blank.

Attachment F

Data Quality Indicators to be Assessed During Reporting

The precision, accuracy, representativeness, completeness, and comparability (PARCC) parameters are specific qualitative and quantitative indicators of data quality. Performance goals (often numeric) that are consistent with other program data quality objectives (DQOs) are typically established for these parameters.

1. Precision Precision measures the reproducibility of measurements under a given set of conditions. It is a quantitative measure of the variability of a group of measurements (that are supposed to be identical or at least very similar) compared to their average value. Sources of variance may include sample heterogeneity, sampling error and analytical error.

Precision is usually stated in terms of standard deviation (e.g., precision of an analytical method), coefficient of variation, error ratio, relative percent difference (RPD) or normalized difference between two values. Precision is determined in the laboratory by evaluating laboratory duplicates, matrix spike duplicates, or replicate measurements of the sample or standard. Precision measurements for overall sampling, measurement, and analytical testing are evaluated through field duplicates or split samples. The comparison of calculated precision for the different types of QC samples (e.g., laboratory replicates, matrix spike duplicates, field duplicates) can be used to assess potential matrix effects. Precision equations are included in the chemical and radioanalytical data validation checklists.

Analytical precision goals are method-specific and are usually approximately 20% RPD or less. Precision goals for field duplicates are approximately twice the analytical precision goal. Precision goals are included in the chemical and radioanalytical data validation checklists. Precision can be controlled and optimized in many ways, including through the consistent use of field and analytical SOPs.

2. Accuracy Accuracy is a quantitative measure of the relationship of reported data compared to the true or expected values, and is affected by a combination of random and systematic error. Sources of this error may include the sampling/measurement process, field or laboratory contamination, preservation, handling, sample matrix, sample preparation and analysis. Data interpretation and reporting may also be significant sources of error.

Accuracy is determined in the laboratory by evaluating the recoveries of analytes spiked into samples, including surrogate spikes, matrix spikes, laboratory control samples (LCSs), and radioactive tracers and carriers, and is typically expressed as percent recovery, the average (arithmetic mean) of the percent recovery, or the normalized difference between the real and expected results. The comparison of calculated recoveries for the different types of spiked QC samples (e.g., surrogate spikes, LCSs, matrix spikes) can be used to assess potential matrix effects. Accuracy measures for overall sampling, measurement, and analytical testing are evaluated through the use of standards, blank samples (e.g., method, instrument, calibration, and trip blanks), background samples, and/or external performance evaluation (PE) samples. Accuracy equations are included in the chemical and radioanalytical data validation checklists.

ENV009.01 F-1 Attachment F

Accuracy goals are method-specific and can be highly variable. Accuracy goals for many analyses range from 75 to 125% recovery. Accuracy goals are included in the chemical and radioanalytical data validation checklists. For both field and laboratory measurements, accuracy can be controlled and optimized in many ways, including through the performance of routine and systematic calibration procedures and the use of SOPs.

3. Representativeness Representativeness is the degree to which data represent a characteristic of a population, a parameter variation at a sampling point or an environmental condition. Representativeness is a qualitative parameter that is most concerned with proper design of the measurement program. For example, sample measurement locations may be biased (judgmental) or unbiased (random or systematic). For the SDA environmental monitoring program, the sample locations have been predetermined and are already biased.

Representativeness for the monitoring program is also a function of the sample collected or measurement made at each of the predetermined locations. This is usually dependent on sampling/measurement techniques or the fieldwork program, and is not typically controlled by the laboratories. For example, groundwater purging and collection methods can affect the representativeness of the sample with respect to the groundwater feeding the well. Field blanks such as equipment blanks and trip blanks can provide information about representativeness (e.g., contamination found in these blanks that is also found in the investigative field samples could indicate that the sample results are not representative of the field conditions and instead represent some other influence).

Analytical laboratories can affect representativeness through the use of sub-samples or aliquots from collected samples. Parent samples should be subjected to thorough homogenization prior to sub-sampling to ensure unbiased measurements within the laboratory. Sample duplicates prepared in the laboratory are one measure of representativeness. Analytical blanks such as method blanks, instrument blanks, and reagent blanks can provide information about representativeness, as described above for field blanks.

Representativeness of the SDA environmental samples is optimized by following standardized procedures. However, certain field experiences are not fully controllable and some of these can affect representativeness (e.g., collecting groundwater samples from low-recharge and low-volume wells and collecting surface water samples from areas of low flow). Representativeness is qualitatively assessed as a result of field and laboratory audits, program oversight, and data review and reporting, which collectively evaluate sample/measurement collection, handling, and analysis with respect to planning documents, SOPs, and the laboratories’ QA manuals and practices. To some extent, representativeness is quantitatively assessed by routine statistical assessments of results.

4. Completeness Completeness is defined as the percentage of measurements performed that are judged to be valid. Valid data are data that are not rejected for failure to meet project DQOs. Critical locations, samples, analyses, and/or measurements typically have higher completeness goals than noncritical ones. For the SDA environmental monitoring program, critical samples, locations, analyses, and/or measurements are considered to be the following:

ENV009.01 F-2 Attachment F

SDA Monitoring Type Critical Samples/Locations Critical Analyses/Measurements

Groundwater sampling All Tritium, VOCs, gross alpha, gross beta

Groundwater elevations Piezometers near the slurry wall Water elevation Slit-trench wells

Trench leachate elevations All Water elevation

Surface water sampling All except background All (tritium, gross alpha, gross beta)

Storm water sampling All (outfall W01) SPDES permit parameters

Environmental TLD All except background Gamma exposure monitoring

Analytical completeness is the quantitative measure of valid data obtained from the analytical process compared to the amount that was expected to be obtained. Overall completeness for the program is the quantitative measure of valid data obtained for a sampling/measurement round compared to the data required to be obtained.

For this program, the completeness goal for critical analyses is 100%, and the goal for noncritical analyses is 90%. Completeness can be controlled and optimized in several ways. For this program, analytical completeness can be enhanced by careful communication with the analytical laboratories (including the environmental TLD vendor). Completeness for the fieldwork can be enhanced through the use of sampling/measurement procedures that promote the collection of all samples/measurements for all analyses/tests.

5. Comparability Comparability is a qualitative measure of the confidence with which one set of data can be compared to another. Sample/measurement data should be comparable to other measurement data for similar samples and sample conditions. Characteristics that make comparison possible include method performance and PE samples; QC samples; standardized reporting formats; consistency of units; and standardized sample/measurement collection, preparation, and analysis procedures. In addition, for the SDA environmental monitoring program, comparability can be enhanced by using collection/measurement and analysis techniques that are as similar as practicable to previous techniques used under the program.

Certain elements pertinent to comparability have already been incorporated into the monitoring program (e.g., consistency of units, the use of collection and analysis techniques that are similar to historical techniques, laboratory use of standards) and might not be specifically assessed during program audits and data review/reporting. Other elements pertinent to comparability are typically assessed as a result of field and laboratory audits, program oversight, and data review and reporting. Comparability also can be quantitatively assessed by routine statistical assessments of results.

ENV009.01 F-3

This page intentionally left blank.

West Valley Site Management Program Page 1 of 4 ENVIRONMENTAL MONITORING PROCEDURE 01/04/2012

TITLE: Verification and Validation of Radioanalytical Data ENV010.01

1.0 PURPOSE

This procedure establishes the methods for verifying and validating radioanalytical data, and developing a preliminary assessment of data quality and usability.

2.0 SCOPE

This procedure defines the methods and requirements for:

 Verifying and validating radioanalytical data

 Developing a preliminary assessment of data quality and usability

Formal assessment and reporting of SDA data will be performed using validated data. This procedure does not address data reporting itself or other aspects of data quality assessment (e.g., statistical assessment and comparison of data to regulatory standards). Those activities are addressed in procedure ENV009, Assessment and Reporting of SDA Data.

3.0 EQUIPMENT AND SUPPLIES

The equipment/supplies needed for this task include tabulated radioanalytical data, hard-copy data package, Radioanalytical Data Verification and Validation Checklist and Summary (Attachment 1), and a calculator.

4.0 DEFINITIONS

4.1 Data Quality Assessment - The scientific and statistical evaluation of data sets to determine if data are of the right type, quality and quantity to support their intended use, and are also known as a determination of data usability. Results of data verification and validation, field information, assessment reports, and historical project data are combined to determine data usability for the intended decisions.

4.2 Data Validation - The process that evaluates data to determine the presence or absence of an analyte, and establishes the uncertainty of the measurement process for contaminants of concern. Data validation qualifies the usability of each datum by comparing the data produced with the measurement quality objectives and any other analytical process requirements established for a project. ENV010.01 Page 2 of 4

4.3 Data Verification - The process that evaluates whether laboratory conditions and operations were compliant with the analytical scope of work (SOW), work plan, sampling and analysis plan (SAP), and/or quality assurance project plan (QAPP). Data verification compares the data package with those requirements (compliance), checks for consistency and comparability of the data throughout the package, and checks for completeness of the results by ensuring that all necessary documentation is available.

5.0 HEALTH AND SAFETY

No specific health and safety requirements apply to verifying and validating radioanalytical data.

6.0 QUALITY REQUIREMENTS

The key quality requirements applicable to the verification, validation, and preliminary quality/usability assessment of radioanalytical data are described below.

6.1 Data verification, validation, and preliminary assessment of data quality and usability shall be conducted in accordance with:

 The guidance in the Multi-agency Radiological Laboratory Analytical Protocols Manual (MARLAP manual); EPA QA/G-8, Guidance on Environmental Data Verification and Data Validation; and EPA QA/R-5, EPA Requirements for Quality Assurance Project Plans.

 Applicable analytical and sampling methods identified in HASL-300 and SW-846.

 Applicable or pertinent requirements have been integrated into this procedure.

6.2 At a minimum, manual manipulation, handling, and validation of data will be double-checked by the person handling the data. For example, calculations made for particular analytical performance indicators will be double-checked to ensure that they were performed accurately, assigned data qualifiers will be checked to be sure they were assigned correctly, and so on.

6.3 In general, radioanalytical data will be used and reported in the same form and with the same number of significant figures as originally reported to E&E by analytical laboratories.

7.0 PROCEDURE

7.1 Radioanalytical Data Verification and Validation

7.1.1 Assemble the hard-copy data package and original electronic data deliverable (EDD) from the laboratory for the radioanalytical data set.

ENV010.01 Page 3 of 4

7.1.2 Assemble the technical scope of work, work plan, SAP, and/or QAPP for the project as well as any applicable regulatory permits or requirements, which together will detail the project objectives, data quality objectives (DQOs), and numeric data quality indicators for the work.

7.1.3 Ensure that the radioanalytical data have been tabulated in a way that allows for clear review and assignment of interim and final data qualifiers.

7.1.4 Perform radioanalytical data verification and validation in accordance with the standard checklist in Attachment 1.

7.2 Preliminary Radioanalytical Data Quality Assessment

7.2.1 Following data verification and validation, assemble the completed Radioanalytical Data Verification and Validation Checklist and Summary, field information (such as data sheets, field logbooks), and historical project data. If available, also assemble the results of other data assessments such as statistical assessments and comparisons to regulatory standards. Most of those assessments are intended to be performed on validated data (see procedure ENV009) and therefore might not be available.

7.2.2 Review the information to determine whether the radioanalytical data satisfy the original project objectives, DQOs, and numeric data quality indicators established for the work. At a minimum, determine whether and how the data satisfy (or do not satisfy) the precision, accuracy (bias), representativeness, completeness, and comparability (PARCC) objectives for the project. In many cases, historical data, trends, and expected data ranges can be used to evaluate the representativeness and comparability of the results. Evaluate the sensitivity of the results to verify that the detection limits are consistent with historical results and project DQOs.

7.2.3 Preliminarily determine whether the data are usable for their intended purpose for the project and whether the data can be used to make decisions regarding the SDA. Further investigate data points that are not usable in order to determine whether additional radioanalysis or other examination of the data can improve its usability. (However, note that the process of data verification and validation provides the best opportunity for improving data quality in the time period immediately following data collection and analysis.)

7.3 Reporting on Radioanalytical Data Verification, Validation, and Quality/Usability

7.3.1 Summarize the results of radioanalytical data verification, validation, and quality/usability assessment in the data report provided to NYSERDA. Ensure that data qualifiers are defined and that qualified data are described and addressed.

7.3.2 Assemble the final verified and validated data into electronic and hard-copy tables per procedure ENV009.

ENV010.01 Page 4 of 4

8.0 RECORD KEEPING

The project files will include the following documentation:

 Electronic and hard copies of data packages and data files provided by radioanalytical laboratories.

 Records of adjustments made to analytical data as a result of data verification and validation.

 Both hard and electronic copies of reports provided to NYSERDA related to data verification, validation, and quality/usability assessment.

 A copy of completed Radioanalytical Data Verification and Validation Checklist and Summary reports.

9.0 REFERENCES AND BIBLIOGRAPHY

9.1 U.S. Environmental Protection Agency (EPA), et al., 2004, Multi-agency Radiological Laboratory Analytical Protocols Manual (MARLAP), Washington, DC.

10.0 ATTACHMENT

10.1 Attachment 1: Radioanalytical Data Verification and Validation Checklist and Summary ATTACHMENT 1

Radioanalytical Data Verification and Validation Checklist and Summary

This page intentionally left blank. Attachment 1

Radioanalytical Data Verification and Validation Checklist and Summary Version 2007

Date: ______Validated by: ______

Project Name: ______Project No.: ______Laboratory: ______

Laboratory Reference No. (SDG, Job, etc.): ______

Analyses: ______Sample Date: ______

Sample Medium: ______

Sample Numbers E & E Sample ID Lab Sample ID Sample ID Lab Sample ID

______

Analytical Level Designated by Project: ______Analytical Level Achieved: ______

Validation Complete (validator’s signature/date): ______

ENV010.01 A-1 Attachment 1

Background This checklist is an approach to radioanalytical data verification and validation for data generated for NYSERDA programs at the Western New York Nuclear Service Center. It is based on a combination of current concepts in federal guidance such as the recent Multi-Agency Radiological Laboratory Analytical Protocol Manual (the MARLAP manual, EPA 2004)) and other preexisting approaches, including West Valley Demonstration Project procedures for data validation. WVDP protocols have been considered because there is a strong historical tie between the NYSERDA and WVDP programs at the Center and NYSERDA maintains a large volume of data that have been validated in accordance with WVDP procedures.

The MARLAP approach to radioanalytical data verification and validation is based on a rigorous, performance-based approach to obtaining data ― i.e., one that considers analytical data needs and requirements during all phases of the project process, from directed planning through implementation and assessment. Consequently, many of the computations and data validation criteria specified by MARLAP are based on decision criteria such as action levels (per radionuclide and sample matrix) and the “gray region” (defined in the MARLAP manual), and using concepts particular and unique to the MARLAP process such as “method uncertainty” (not to be confused with measurement uncertainty) and “critical value” (minimum quantifiable concentration).

The approach herein is an interim approach based on elements of both MARLAP and other preexisting approaches that have been integrated to the extent possible. The integration considered the following: 1) the MARLAP approach is in the early stages of adoption and/or acceptance and it is uncertain how much or whether data validation philosophies will change in the future to meet it, 2) individual programs at the Center have not necessarily been performance-based, 3) analytical laboratories are not yet necessarily prepared to determine or report essential MARLAP concepts such as method uncertainty and critical value, and 4) the WVDP procedure for data validation has been used for the majority of the data that NYSERDA maintains. Certain MARLAP terminology is used where feasible (such as the use of the terms data verification and data validation; use of “combined standard uncertainty” for what previously has been commonly known as “total propagated uncertainty”). However, performance-based acceptance criteria for evaluating QC samples that are based on the MARLAP-defined concept of method uncertainty have not been included. The validator is referred to the MARLAP manual if strict adherence to the MARLAP protocol is required and practicable. This checklist can be revised in the future to more strictly follow the MARLAP protocol when/if warranted.

For the purposes of this protocol, data verification will be considered to be the process that evaluates whether laboratory conditions and operations were compliant with the analytical scope of work (SOW), work plan, sampling and analysis plan, and/or quality assurance project plan (QAPP). Data verification compares the data package with those requirements (compliance), checks for consistency and comparability of the data throughout the package, and checks for completeness of the results by ensuring that all necessary documentation is available.

Data validation will be considered to be the process that evaluates data to determine the presence or absence of an analyte and establishes the uncertainty of the measurement process for contaminants of concern (not to be confused with reported measurement uncertainty). Data validation qualifies the usability of each datum by comparing the data produced with standard validation criteria, laboratory criteria, and any specific measurement quality objectives (MQOs) and analytical process requirements established for an individual project. Both data verification and data validation elements have been integrated into the checklist.

The data verification and validation process is not intended to evaluate all aspects of analytical operations and the generation of analytical data. Criteria such as instrument calibration (and all that it entails), method applicability, successful participation in national performance evaluation programs, QA

ENV010.01 A-2 Attachment 1 management, and others are better evaluated during laboratory procurement and any scheduled audits and for the most part are not considered in detail in this protocol.

The checklist is intended to be used by validators that have received training and instruction in radioanalytical data validation. This checklist and summary is not itself a training device and does not contain all of the information and guidance the validator will need to make validation judgments. Ultimately, data validation decisions are made using a combination of objective and subjective considerations based on experience.

Instructions

1. Assemble a table of the data provided by the laboratory, including the analytical result, expanded uncertainty (roughly analogous to a 2σ uncertainty), and minimum detectable concentration (MDC) for each sample and parameter. Allow room to assign data qualifiers for each result.

2. Complete the checklist for each parameter analyzed. Answer as applicable:

√/Y = Yes N = No N/A = Not applicable NP = Not performed NR = Not required

The checklist is designed such that “no” answers will stand out and be cause for further scrutiny and potential data qualification.

3. Assign interim data qualifiers in accordance with the checklist results and the qualifiers below.

Data Verification

E = A notice to the validator that something was noncompliant.

Remove or replace this qualifier during data validation, if possible, based on the validator’s interpretation of the effect of the noncompliance on the data’s integrity.

Data Validation

U = Analyte considered not detected above the reported MDC (or minimum detectable activity [MDA]).

J = An uncertain or estimated result.

R = A rejected result. The data are determined to be unusable.

Caution: Data should only be rejected after careful consideration of all factors and inputs. Laboratories are required to have QA programs designed to ensure that most quality problems are caught at the lab and resolved prior to reporting the data. Data rejection should be considered to be an atypical event.

4. When verification and validation are complete, review the checklist and the interim data qualifiers and assign final data qualifiers in consideration of the findings from all tests and criteria, patterns (or

ENV010.01 A-3 Attachment 1

lack thereof) of findings and problems in batches of samples, and validator judgment. The final validation decisions should address the fact that the broader purpose of validation is to contribute to the total data collection process and achieve an overall assessment of data quality and usability. The validator should examine the full range of data available and use relationships among the data elements to support the acceptance and use of data that falls outside method or contract specifications and data validation guidance.

5. Summarize the results of data verification and validation in a stand-alone report or as text integrated into the project data report. Include the following at a minimum and in accordance with the requirements of the project:

 A table of validated sample IDs, analytical results, expanded uncertainties, MDCs, and associated final qualifiers.

 A narrative summary of the key results of verification and validation, including: – Key findings that affected verification and validation, such as missing information that could not ultimately be obtained, positive steps taken by the laboratory to ensure compliance with the analytical SOW under adverse circumstances, analytical nonconformances, method changes or modifications, and corrective actions driven by the laboratory and/or the validator. – A summary of QC sample performance and any effects on the data; e.g., that the results of all laboratory control samples (LCSs) were acceptable. – A summary and explanation of all qualified data and the meaning and definition of assigned qualifiers. – Changes made to standard validation criteria and their reasons. – A summary of other key sample management system actions or findings that affected data and data review; e.g., batching, analytical chain-of-custody (COC), electronic data transfer and assembly.

6. Assess and summarize overall data quality and usability in accordance with established guidance and the project’s data quality objectives (DQOs).

ENV010.01 A-4 Attachment 1

Radioanalytical Data Verification and Validation Checklist Analysis Verification and Validation Item A. Project/Contract Information The following information is available to conduct data validation:  Laboratory data package  Contract or project work requirements (e.g., task order, project SOW, QAPP, SAP, work plan)  Analytical work requirements (e.g., analytical SOW, subcontract, method SOPs)  Sample analysis requests (e.g., COC) Explanation/Comment:

Action: Obtain missing information before continuing with data verification & validation

B. Data Package Completeness Data package contains the information required by analytical SOW. Explanation/Comment:

Action: Obtain missing information necessary to complete verification & validation in accordance with correct analytical level.

C. Cover Letter and Case Narrative Cover letter and case narrative contain a summary of analytical performance, data quality, definitions for data qualifiers or flags, any problems encountered, procedure modifications, and other noteworthy results. Explanation/Comment:

Action: Obtain missing information necessary to complete verification & validation. Resolve with lab any outstanding issues.

D. Compliance with Analytical SOW/Subcontract and COC 1. Lab performed all analyses required by analytical SOW/subcontract. 2. Lab performed all analyses required by COC (or other sample request form). Explanation/Comment:

Action: Investigate and resolve missing or incorrect analyses. ENV010.01 A-5 Attachment 1

Analysis Verification and Validation Item

E. Completeness of Supporting Information Reported for Analytical Results Note: This section addresses some key verification/validation items that are not otherwise addressed in other sections. 1. Each sample was identified by a unique project sample ID in accordance with project SOW, work plan, QAPP, etc. 2. Each sample result is accompanied by, as applicable:  Lab sample ID  Batch ID  Measurement uncertainty (1σ) and expanded uncertainty (2σ) (also addressed in items G and H)  Sample volume  Matrix  Collection date  Aliquot volume  Percent moisture  Preparation and/or separation chemistry date and procedures  Counting/analysis date  Count duration   3. Applicable lab QA and QC sample criteria are provided (e.g., acceptance criteria for LCSs, lab rep precision, method blanks, chemical yields, etc.). Explanation/Comment:

Action: a. Obtain missing information necessary to complete verification & validation. Resolve with lab any outstanding issues. b. If supporting information is still incomplete or conflicting, consider assigning data qualifiers commensurate with the effect on the reliability of the data.

F. Procedures/Methods 1. Proper procedures/methods were used. 2. Any deviations were acceptably noted. Explanation/Comment:

Action: The validator may take procedures/methods into account when assigning qualifier codes to analytical results.

G. Calculation/Assignment of Detection Limit and Uncertainty 1. If warranted, calculate achieved detection limits (e.g., MDCs, MDAs) and compare with reported detection limits (MDCs, MDAs). ENV010.01 A-6 Attachment 1

Analysis Verification and Validation Item 2. Combined standard uncertainty (1σ uncertainty) has been calculated 2. and/or assigned correctly for each result. 3. Expanded uncertainty (combined standard uncertainty times a coverage factor; assume a coverage factor of 2 unless advised otherwise) has been calculated and/or assigned correctly. 4. The reported combined standard uncertainty is acceptable for the analysis, MDC, and reported sample result. (This can be determined if the approximate expected uncertainty is provided by the lab for each analyte, MDC, and analyte level or there is prior experience with the lab, analysis, MDC, and analyte level from which to draw inferences. In general, relatively large uncertainties with respect to the MDC and/or the reported result suggest a potential problem with interferences, small sample sizes, short count times, or other qualities. Also see item H.) Explanation/Comment:

Action: Resolve any problems with detection limits or uncertainty expressions. After completing Section H, consider assigning appropriate qualifier codes if the quality or meaning of the reported detection limit or uncertainty is in question and cannot be resolved.

H. Comparison of Result, Detection Limit, and Uncertainty 1. Reported MDCs were ≤ contract-required detection limit (CRDL). Action: If “no,” request that the sample be submitted for recounting or reanalysis, whichever is appropriate, until this requirement is satisfied or sufficient reason is provided for why the requirement cannot be met. For cases where item cannot be satisfied, scrutinize results with respect to the reported MDC, the CRDL, and other reported results for that analyte to determine potential impacts on the usability of the data. 2. The result > its MDC. 3. The result > its expanded uncertainty (or 2σ uncertainty). Action: a. If “no” to either item H2 or H3, assign a “U” qualifier to the result. b. For a result below the MDC but where the MDC exceeded the CRDL, consider assigning a “J” qualifier in addition to the “U” qualifier based on the degree of uncertainty regarding the result with respect to project requirements. c. For a result above the MDC but where the MDC exceeded the CRDL, consider assigning a “J” qualifier based on the degree of uncertainty regarding the result with respect to project requirements. 4. The uncertainty associated with a U-qualified result < CRDL. Action: If “no,” assign a “J” qualifier to the result. 5. The MDC associated with a U-qualified result < the associated expanded uncertainty (or 2σ uncertainty). [Do Not Use this Validation Item.] Action: If “no,” assign a “J” qualifier to the result. [Do not use this Item.] 6. For non-U-qualified results, the associated uncertainty ≤ 50% of the result. Action: If “no,” assign a “J” qualifier to the result. 7. For negative results, the absolute value of the result < its expanded uncertainty (2σ). ( | Negative result | > its expanded uncertainty indicates a range of possible results that can only be negative, which indicates a potential data quality problem most likely due to the background count.) Action: If “no,” assign a tentative “J” qualifier (in addition to the “U” qualifier) to the result and continue with items H8 and H9. 8. The absolute value of each negative result < its 3σ uncertainty. ENV010.01 A-7 Attachment 1

Analysis Verification and Validation Item 9. If “no” to items H7 and H8, instrument calibration and performance check results, including daily backgrounds for each detector, were reviewed for patterns or other systematic effects potentially contributing to such results. Action: Consider converting tentative “J” qualifiers from item H7 to permanent “J” qualifiers if the answer to item H8 is “no” and the review conducted for item H9 indicates that the negative results are influenced by potential systematic instrumentation effects.

Consider assigning an “R” qualifier instead of a “J” qualifier if the negative result is deemed to be unreliable because the answer to item H7 and/or H8 is “no” and the review conducted for item H9 indicates unacceptable or inexplicable instrumentation effects. Explanation/Comment:

I. Units Units are appropriate. Explanation/Comment:

Action: Resolve any problems with units. Consider assigning an appropriate qualifier code if units cannot be resolved and are uncertain.

J. Significant Figures Significant figures are appropriate. Explanation/Comment:

Action: Resolve any issues with reported significant figures. Consider assigning an appropriate qualifier code if the significant figures used are inappropriate.

K. Holding Times 1. Required holding times were met. 2. Results reported for analyses where more than three half-lives elapsed between sample collection and analysis were evaluated for holding time effects. Explanation/Comment:

Action:

ENV010.01 A-8 Attachment 1

Analysis Verification and Validation Item a. Consider assigning a “J” qualifier for results where more than one but fewer than three half-lives elapsed between sample collection and analysis (and where the lab did not back-adjust for decay). An “R” qualifier might be appropriate for results below the MDC. b. Consider assigning an “R” qualifier for results where more than three half-lives elapsed between sample collection and analysis (and where the lab did not back-adjust for decay).

L Sample Preservation 1. Preservatives were appropriately used during sample collection. 2. Lab checked sample pH upon sample receipt and noted the value in the data package documentation. Explanation/Comment:

Action: a. Consider assigning a “J” qualifier to sample results where inappropriate preservatives were used and the resulting effect was an overall uncertainty in the data. b. Consider assigning an “R” qualifier to sample results where inappropriate preservatives were used and the results are deemed to be unreliable.

M. Sample Custody Documentation 1. The data package sample custody documentation includes as applicable:  Field COC forms  Lab COC forms  Shipping documentation  Other: 2. The samples were in an individual’s custody between original collection and final disposition (destruction, disposal, archiving). 3. Dates and sample numbers agree and are consistent throughout the custody documentation. Explanation/Comment:

Action: Obtain any outstanding information before proceeding with verification & validation. Consider assigning an appropriate qualifier code if custody issues are considered to affect data reliability.

N. Internal Laboratory QA ― Instrument Calibration, Performance Checks, and Control 1. Each detector was in calibration according to an approved calibration schedule. 2. Calibration sources were traceable to NIST. 3. Calibration results and records are acceptable. 4. Performance check sources were identified. 5. Instrument high voltages were appropriately selected and documented. 6. Calibration and analytical geometries were equivalent and acceptable. 7. Daily instrument performance checks were made. 8. Appropriate background counts were run for the samples. 9. Appropriate efficiency determinations were made for the samples. 10. Instrument control charts are acceptable. 11. Mass attenuation (self-absorption) and alpha/beta crosstalk corrections ENV010.01 A-9 Attachment 1

Analysis Verification and Validation Item were determined during calibration for alpha/beta gas-flow proportional counting. 12. For gamma spec analyses, full-width of a peak at half maximum (FWHM) and/or full width at tenth maximum (FWTM) were reported and are acceptable. 13. Quench curves were developed during calibration for liquid scintillation analysis. 14. Instrument calibration, performance check, and other control data apply to the detectors actually used for analyses and match the analytical dates. Explanation/Comment:

Action: a. Obtain any missing information before proceeding with verification & validation. b. Consider assigning a “J” qualifier to sample results obtained from a questionable detector and where the result is an overall uncertainty in the data. c. Consider assigning an “R” qualifier to sample results for which no traceability can be made to acceptable calibration or performance check results.

O. Internal Laboratory QA ― Management Review and Corrective Actions 1. Data were reviewed and approved by laboratory line management. 2. Lab provided adequate documentation of any corrective actions implemented during analysis. Explanation/Comment:

Action: Review corrective actions to determine potential impacts on data and data usability. Consider assigning a qualifier code as appropriate.

P. Internal Laboratory QC ― Laboratory Control Samples (LCSs)

ENV010.01 A-10 Attachment 1

Analysis Verification and Validation Item 1. Lab analyzed at least one LCS for each analysis type in each SDG of approximately 20 samples or less. 2. LCS was subjected to entire analytical process. 3. LCS contained the proper analyte (must be the analyte of interest or one with identical chemical properties). 4. Lab reported the known activity in the spike and the LCS result. 5. Lab reported recovery results. 6. Percent recovery calculations are correct. 7. LCS recovery results are within lab acceptance criteria. 8. If LCS was evaluated other than by recovery, lab reported the bias for the LCS result and spike quantity. Equation/measure of bias used: ______9. Bias calculations are correct. 10. LCS bias results are within lab acceptance criteria. 11. If not adequately determined and reported by lab, validator has determined bias (e.g., recovery or normalized difference) between LCS result and spike quantity (see Attachment A). Equation/measure of bias used: ______12. LCS bias results are within acceptance criteria. Explanation/Comment:

Action: a. When an LCS result is questionable, is outside warning limits but within control limits, or otherwise does not meet stated criteria (see above and Attachment A), consider assigning a “J” qualifier to associated sample results. Consider other QC performance in this determination (e.g., other QC performance associated with judging bias or accuracy for the analysis). b. Consider assigning a “U” or “UJ” qualifier to sample results ≥ their MDC and < approximately 2x the MDC if LCS results suggest a potential false positive associated with analysis bias. Instead use a “J” qualifier if LCS results suggest a potential false negative associated with analysis bias. c. Consider assigning an “R” qualifier when LCS results are outside control limits or other criteria such that the results for investigative samples are unreliable. d. Use professional judgment to assign qualifiers when an LCS result is questionable or does not meet stated criteria and associated sample results are < their MDC but the MDC exceeded the CRDL.

Q. Internal Laboratory QC ― Method Blank or Reagent Blank Samples 1. Lab analyzed at least one method blank and/or reagent blank for each analysis type in each SDG of approximately 20 samples or less. 2. Blank samples were subjected to entire analytical process. 3. Lab blank sample results are within lab acceptance criteria. 4. Lab blank sample results are negative or less than the reported MDC. 5. Lab blank sample results are < their expanded uncertainty (2σ uncertainty). 6. Lab blank sample results are less than ½ CRDL. 7. As an alternative to items Q3 to Q5, lab blank contamination is within the warning and control limits for Zblank and/or normalized difference (see Attachment A). ENV010.01 A-11 Attachment 1

Analysis Verification and Validation Item 8. Sample results associated with lab blanks that do not meet acceptance criteria have been evaluated to determine the magnitude of the sample result with respect to both the sample-specific MDC and the concentration in the blank. Explanation/Comment:

Action: a. When a blank result is questionable, is outside warning limits but within control limits, or otherwise does not meet stated criteria (see above and Attachment A), consider assigning a “J” qualifier to associated sample results that are ≥ their MDC and no more than 2 to 5x the blank concentration. Consider other QC performance in this determination (e.g., other QC performance associated with judging bias or accuracy for the analysis). In general, sample results ≥ their MDC (assuming the MDC meets the CRDL) and more than 5x the concentration of a questionable blank are considered to be unaffected by the blank results. b. Consider assigning a “U” or “UJ” qualifier to sample results ≥ their MDC and < approximately 2 to 5x the MDC if blank results suggest a potential false positive associated with analysis bias. c. Consider assigning an “R” qualifier when blank results are outside control limits or other criteria such that the results for investigative samples are unreliable. d. Use professional judgment to assign qualifiers when a blank result is questionable or does not meet stated criteria and associated sample results are < their MDC but the MDC exceeded the CRDL.

R. Internal Laboratory QC ― Lab Replicate Samples (LREs) 1. Lab analyzed at least one LRE for each analysis type in each SDG of approximately 20 samples or less. 2. Each LRE was a laboratory-generated split of an SDG sample and the LRE sample ID is traceable to the sample ID of the original sample. 3. Lab reported the precision between the LRE and original sample result. Equation/measure of precision used: ______4. Precision calculations are correct. 5. LRE precision results are within lab acceptance criteria. 6. If not adequately determined and reported by lab, validator has determined precision for the original and LRE results. Equation/measure of precision used: ______7. Precision results are within acceptance criteria. Explanation/Comment:

Action: ENV010.01 A-12 Attachment 1

Analysis Verification and Validation Item a. When an LRE result is questionable, is outside warning limits but within control limits, or otherwise does not meet stated criteria (see above and Attachment A), consider assigning a “J” qualifier to associated sample results that are ≥ their MDC. Consider other QC performance in this determination (e.g., other QC performance associated with judging precision for the analysis). b. Use professional judgment to assign qualifiers when an LRE result is questionable or does not meet stated criteria and associated sample results are < their MDC. c. Consider assigning an “R” qualifier when LRE results are outside control limits or other criteria such that the results for investigative samples are unreliable. d. Use professional judgment to assign qualifiers when an LRE result is questionable or does not meet stated criteria and associated sample results are < their MDC but the MDC exceeded the CRDL.

S. Internal Laboratory QC ― Analytical Yields 1. Lab reported analytical yields when tracers and/or carriers were used. 2. Lab reported the known activity in the tracer or carrier and the recovered amount. 3. Lab reported recovery results. 4. Percent recovery calculations are correct. 5. Yields are within lab acceptance criteria. Explanation/Comment:

Action: a. When a yield result is questionable, is outside warning limits but within control limits, or otherwise does not meet stated criteria (see above and Attachment A), consider assigning a “J” qualifier to associated sample results. Consider other QC performance in this determination (e.g., other QC performance associated with judging bias or accuracy for the analysis). Sample results typically should not be qualified on the basis of yield performance alone. b. Consider assigning a “U” or “UJ” qualifier to sample results ≥ their MDC and < approximately 2x the MDC if yield results suggest a potential false positive associated with analysis bias. Instead use a “J” qualifier if yield results suggest a potential false negative associated with analysis bias. c. Consider assigning an “R” qualifier when yield results are outside control limits or other criteria such that the results for investigative samples are unreliable. d. Use professional judgment to assign qualifiers when a yield result is questionable or does not meet stated criteria and associated sample results are < their MDC but the MDC exceeded the CRDL.

T. External Laboratory QC and Field QC ― Matrix Spike/Matrix Spike Duplicate (MS/MSD) Samples 1. At least one MS/MSD has been collected and analyzed for each analysis type in each SDG of approximately 20 samples or less. (Refer to analytical SOW to determine for which analyses MS/MSDs are required. They are not typically required for all analyses.) 2. The MS and MSD volumes were provided by the field team to the lab and the MS/MSD sample is traceable to the sample number of the original field sample. 3. The MS and MSD were spiked with the proper analyte (must be the analyte of interest or one with identical chemical properties). 4. Lab reported the known activity in the spike, the MS and MSD results, and the results for the original (unspiked) sample. 5. Lab reported the recovery for the MS and MSD samples. ENV010.01 A-13 Attachment 1

Analysis Verification and Validation Item 6. Percent recovery calculations are correct. 7. MS and MSD recovery results are within lab acceptance criteria. 8. If MS and MSD bias was evaluated other than by recovery, lab reported the bias between the MS result and spike quantity, and between the MSD result and spike quantity. Equation/measure of bias used: ______9. Bias calculations are correct. 10. Bias results for the MS and MSD analyses are within lab acceptance criteria. 11. If not adequately determined and reported by lab, validator has determined bias for the MS and MSD results. Equation/measure of difference used: ______12. MS and MSD biases are within acceptance criteria. 13. Lab reported the precision between the MS and MSD results. Equation/measure of precision used: ______14. Precision calculations are correct. 15. MS/MSD precision results are within lab acceptance criteria. 16. If not adequately determined and reported by lab, validator has determined precision for the MS and MSD results. Equation/measure of precision used: ______17. Precision results are within acceptance criteria. Explanation/Comment:

Action: a. When MS or MSD bias is questionable, is outside warning limits but within control limits, or otherwise does not meet stated criteria (see above and Attachment A), consider assigning a “J” qualifier to associated sample results. Consider other QC performance in this determination (e.g., other QC performance associated with judging bias/accuracy for the analysis). b. Consider assigning a “U” or “UJ” qualifier to sample results ≥ their MDC and < approximately 2x the MDC if MS/MSD results suggest a potential false positive associated with analysis bias or matrix effects. Instead use a “J” qualifier if MS/MSD results suggest a potential false negative associated with analysis bias or matrix effects. c. When MS/MSD precision is questionable, is outside warning limits but within control limits, or otherwise does not meet stated criteria (see above and Attachment A), consider assigning a “J” qualifier to associated sample results that are ≥ their MDC. Consider other QC performance in this determination (e.g., other QC performance associated with judging precision for the analysis). d. Use professional judgment to assign qualifiers when MS/MSD precision is questionable or does not meet stated criteria and associated sample results are < their MDC. e. Consider assigning an “R” qualifier when MS/MSD results for bias or precision are outside control limits or other criteria such that the results for investigative samples are unreliable. f. Use professional judgment to assign qualifiers when an MS/MSD result (for either bias or precision) is questionable or does not meet stated criteria and associated sample results are < their MDC but the MDC exceeded the CRDL.

U. External Laboratory QC and Field QC ― Field Blank Samples ENV010.01 A-14 Attachment 1

Analysis Verification and Validation Item 1. At least one field blank sample has been collected and analyzed for each analysis type in each SDG of approximately 20 samples or less (as required by project SOW, work plan, and/or QAPP). 2. Field blank sample results are negative or less than the reported MDC. 3. Field blank sample results are < their expanded uncertainty (2σ uncertainty). 4. Field blank sample results are less than ½ CRDL. 5. As an alternative to items U2 to U4, field blank contamination is within the warning and control limits for Zblank and/or normalized difference (see Attachment A). 6. Sample results associated with field blanks that do not meet acceptance criteria have been evaluated to determine the magnitude of the sample result with respect to both the sample-specific MDC and the concentration in the blank. Explanation/Comment:

In general, sample results ≥ their MDC (assuming the MDC meets the CRDL) and more than 5x the concentration of a questionable blank might be unaffected by the blank results depending on the potential contributors to the blank result. b. Consider assigning a “U” or “UJ” qualifier to sample results ≥ their MDC and < approximately 2 to 5x the MDC if blank results suggest a potential false positive associated with analysis bias or field variables. c. Consider assigning an “R” qualifier when blank results are outside control limits or other criteria such that the results for investigative samples are unreliable. d. Use professional judgment to assign qualifiers when a blank result is questionable or does not meet stated criteria and associated sample results are < their MDC but the MDC exceeded the CRDL.

V. External Laboratory QC and Field QC ― Field Duplicate Samples (FDPs) 1. At least one FDP has been collected and analyzed for each analysis type in each SDG of approximately 20 samples or less. 2. Each FDP was a field-generated duplicate of an original investigative sample and is traceable to the original sample. 3. Validator has determined precision for the original and FDP results. Equation/measure of precision used: ______4. Precision results are within acceptance criteria. Explanation/Comment:

ENV010.01 A-15 Attachment 1

Analysis Verification and Validation Item

Action: a. When an FDP result is questionable, is outside warning limits but within control limits, or otherwise does not meet stated criteria (see above and Attachment A), consider assigning a “J” qualifier to associated sample results that are ≥ their MDC. Consider other QC performance in this determination (e.g., other QC performance associated with judging precision for the analysis). b. Use professional judgment to assign qualifiers when an FDP result is questionable or does not meet stated criteria and associated sample results are < their MDC. c. Consider assigning an “R” qualifier when FDP results are outside control limits or other criteria such that the results for investigative samples are unreliable. d. Use professional judgment to assign qualifiers when an FDP result is questionable or does not meet stated criteria and associated sample results are < their MDC but the MDC exceeded the CRDL.

W. Results Calculations Results calculations were performed correctly for each analysis. Explanation/Comment:

Action: Investigate occurrences where calculations cannot be traced or where there are questions regarding the accuracy of the generated results. Adjust final sample results as necessary.

X. Gamma Spectra Review 1. Gamma spectra results agree with reported data. 2. Gamma spectra results were reviewed for the presence of gamma emitters not required to be reported for the project. (Such results should be reported to the client.) 3. Significant peak overlap was low. 4. Peaks were appropriately identified and matched the proper energy. Explanation/Comment:

Action: Resolve any questions regarding gamma spec results. Consider assigning a qualifier code as appropriate.

Y. Transcription and Documentation Consistency 1. There was good agreement among laboratory calculations, instrument printouts, other supporting information, and the reported results. The information is consistent throughout the data package. 2. If “no” to item Y1, corrections have been made to the data package and transferred to the reported results. The validator has coordinated with the laboratory when making such corrections. Explanation/Comment:

Action: Resolve any issues with transcription and documentation consistency. Consider assigning a qualifier code as appropriate.

ENV010.01 A-16 Attachment 1

References

Paar, J.G. and D.R. Porterfield, 1997, Evaluation of Radiochemical Data Usability, ESERMS-5, prepared for U.S. DOE, TN and NM.

Radiochemistry Society, 2005, Data Validation and Laboratory QA, radiometric data validation course, Richland, WA.

URS, 2002, Radioanalytical Data Validation, EM-74, prepared for U.S. DOE WVDP, West Valley, NY.

U.S. EPA, 2004, Multi-Agency Radiological Laboratory Analytical Protocols Manual (MARLAP manual), Washington, DC.

ENV010.01 A-17 Attachment 1

This page intentionally left blank.

ENV010.01 A-18 Attachment 1

Attachment A Numerical Performance Indicator Tests

Blanks

For contamination determination: x Zblank = uc x

Where: x = measured blank activity uc(x) = combined standard uncertainty for the blank

Warning limit for Zblank is ±2. Control limit for Zblank is ±3.

______

Normalized Difference (between a blank value and an investigative sample result):

x1  x2 Z = 2 2 uc x1   uc x2 

Where: Z = statistical difference between two radioanalytical results x1 = measured activity of result 1 x2 = measured activity of result 2 (blank) uc(x1) = combined standard uncertainty for result 1 uc(x2) = combined standard uncertainty for result 2 (blank)

Limits for Comparing Blank and Investigative Sample (typically only meaningful when investigative sample result ≥ its MDC): Acceptable: Z > 3 or Z < -3 Warning limit: 2 < Z <3 or -3 < Z < -2 Control limit: 0 < Z < 2 or -2 < Z < 0

______

ENV010.01 A-19 Attachment 1

Normalized Absolute Difference (between a blank value and an investigative sample result):

x1  x2 Z = 2 2 uc x1   uc x2 

Where: Z = statistical difference between two radioanalytical results |x1 – x2| = absolute value of the difference between result 1 and result 2 x1 = measured activity of result 1 x2 = measured activity of result 2 (blank) uc(x1) = combined standard uncertainty for result 1 uc(x2) = combined standard uncertainty for result 2 (blank)

Limits for Comparing Blank and Investigative Sample (typically only meaningful when investigative sample result ≥ its MDC): Acceptable: Z > 3 Warning limit: 2 < Z <3 Control limit: 0 < Z < 2 ______

LCSs

Normalized Difference (between the spike value and the LCS result):

x1  x2 Z = 2 2 uc x1   uc x2 

Where: Z = statistical difference between two radioanalytical results x1 = measured activity of LCS x2 = known activity of spike uc(x1) = combined standard uncertainty for LCS uc(x2) = expected uncertainty for spike

Limits: When Sample Result ≥ MDC Warning limit for Z is ±2 Control limit for Z is ±3

When Sample Result < MDC Warning limit for Z is -2 Control limit for Z is -3 Positive Z is immaterial ______

ENV010.01 A-20 Attachment 1

Percent Recovery:

SSR %Rec =  100% Sp

Where: %Rec = Percent recovery SSR = Spiked sample result (measured activity of analyte in spiked sample) Sp = Known quantity of analyte (spike) introduced

Acceptable recoveries are typically about 50 to 150% but are analysis-dependent.

Limits: When Sample Result ≥ MDC Warning limit (approximate): %Rec < 80% or %Rec > 120% Control limit (approximate): %Rec < 50% or %Rec > 150%

When Sample Result < MDC Warning limit (approximate): %Rec < 80% Control limit (approximate): %Rec < 50%

______

Yields

Percent Recovery:

%Rec =

Where: %Rec = Percent recovery SSR = Measured quantity of tracer or carrier Sp = Known quantity of tracer of carrier introduced

Acceptable recoveries are typically about 75 to 125% but are lab- and analysis-dependent.

______

ENV010.01 A-21 Attachment 1

MS Bias/Accuracy

Normalized difference (between the spike value and the MS result):

SSR  x  Sp Z = 2 2 2 uc SSR  uc x  uc Sp

Where: Z = statistical difference among the radioanalytical results SSR = Spiked sample result (measured activity of analyte in MS or MSD) x = Measured activity of analyte in unspiked sample Sp = Known quantity of analyte (spike) introduced uc(SSR) = combined standard uncertainty for MS or MSD result uc(x) = combined standard uncertainty for unspiked sample uc(Sp) = expected uncertainty for spike

Limits: When Sample Result ≥ MDC Warning limit for Z is ±2 Control limit for Z is ±3

When Sample Result < MDC Warning limit for Z is -2 Control limit for Z is -3 Positive Z is immaterial

______

ENV010.01 A-22 Attachment 1

Percent Recovery:

SSR  x %Rec =  100% Sp

Where: %Rec = Percent recovery SSR = Spiked sample result (measured activity of analyte in spiked sample) x = Measured activity of analyte in unspiked sample Sp = Known quantity of analyte (spike) introduced

Acceptable recoveries are typically about 75 to 125% but are analysis-dependent.

Limits: When Sample Result ≥ MDC Warning limit (approximate): %Rec < 75% or %Rec > 125% Control limit (approximate): %Rec < 30% or %Rec > 150%

When Sample Result < MDC Warning limit (approximate): %Rec < 75% Control limit (approximate): %Rec < 30% ______

Replicate or Duplicate Samples

(including precision for MS/MSD sample pairs)

Normalized Difference:

x1  x2 Z = 2 2 uc x1   uc x2 

Where: Z = statistical difference between two radioanalytical results x1 = measured activity of result 1 x2 = measured activity of result 2 uc(x1) = combined standard uncertainty for result 1 uc(x2) = combined standard uncertainty for result 2

Warning limit for Z is ±2. Control limit for Z is ±3.

______

ENV010.01 A-23 Attachment 1

Normalized Absolute Difference: (When comparing duplicates or replicates, this is sometimes called Relative Error Ratio)

x1  x2 Z = 2 2 uc x1   uc x2 

Where: Z = statistical difference between two radioanalytical results |x1 – x2| = absolute value of the difference between result 1 and result 2 x1 = measured activity of result 1 x2 = measured activity of result 2 uc(x1) = combined standard uncertainty for result 1 uc(x2) = combined standard uncertainty for result 2

Warning limit for Z is 2. Control limit for Z is 3.

______

Relative Percent Difference:

x1  x2 RPD =  100% x

Where: |x1 – x2| = absolute value of the difference between result 1 and result 2 x1 = measured activity of result 1 x2 = measured activity of result 2  = average activity of result 1 and result 2

General rule-of-thumb Warning limit for RPD for lab replicates (including MS/MSDs) is roughly 30% General rule-of-thumb Control limit for RPD for lab replicates (including MS/MSDs) is roughly 40%

General rule-of-thumb Warning limit for RPD for field duplicates is roughly 40% General rule-of-thumb Control limit for RPD for field duplicates is roughly 50%

Note: RPD is typically a good indicator of difference only when higher relative activities (e.g., at least 5 times the MDC) are involved. ______

ENV010.01 A-24 West Valley Site Management Program Page 1 of 4 ENVIRONMENTAL MONITORING PROCEDURE 01/04/2012

TITLE: Verification and Validation of Chemical Analytical Data ENV011.01

1.0 PURPOSE This procedure establishes the methods to be used for verifying and validating chemical analytical data, and developing a preliminary assessment of data quality and usability.

2.0 SCOPE This procedure defines the methods and requirements for:  Verifying and validating chemical analytical data.  Developing a preliminary assessment of data quality and usability.  Formal assessment and reporting of SDA data will be performed using validated data. This procedure does not address data reporting itself or other aspects of data quality assessment, such as statistical assessment and comparison of data to regulatory standards. Those activities are addressed in procedure ENV009, Assessment and Reporting of SDA Data.

3.0 EQUIPMENT AND SUPPLIES The equipment/supplies needed for this task include tabulated chemical analytical data, hard-copy data package, Data Usability Summary Report (DUSR) template and Method-Specific Checklists (Attachment 1) and a calculator.

4.0 DEFINITIONS 4.1 Data Qualifiers - Letter codes attached to the analytical result to indicate the outcome of the verification and validation process. The follower qualifiers are used for chemical analytical data: J The analyte was positively identified. The associated numerical value is considered estimated. A negative sign added to the “J” indicates a negative bias. A positive sign added to the “J” indicates a positive bias. R The sample results are rejected due to serious deficiencies in the ability to analyze the sample and meet quality control criteria. The presence or absence of the analyte cannot be verified. The datum is rejected and not usable for the purposes of the project. U The analyte was analyzed for but not detected above the associated numerical value. The value is the practical quantitation limit (PQL) or lower limit of detection (LOD) reported by the laboratory. UJ The analyte was analyzed for but not detected above the associated numerical value. This value is considered estimated. 4.2 Data Quality Assessment - The scientific and statistical evaluation of data sets to determine if data are of the right type, quality, and quantity to support their intended use, and are also known as a determination of data usability. Results of data verification and validation, field information, assessment reports, and historical project data are combined to determine data usability for the intended decisions. ENV011.01 Page 2 of 4

4.3 Data Validation - The process that evaluates data to determine the presence or absence of an analyte, and establishes the uncertainty of the measurement process for contaminants of concern. Data validation qualifies the usability of each datum by comparing the data produced with the measurement quality objectives and any other analytical process requirements established for a project. 4.4 Data Verification - The process that evaluates whether laboratory conditions and operations were compliant with the analytical scope of work (SOW), work plan, sampling and analysis plan (SAP), and/or quality assurance project plan (QAPP). Data verification compares the data package with those requirements (compliance), checks for consistency and comparability of the data throughout the package, and checks for completeness of the results by ensuring that all necessary documentation is available.

5.0 HEALTH AND SAFETY No specific health and safety requirements apply to verifying and validating chemical analytical data.

6.0 QUALITY REQUIREMENTS The key quality requirements applicable to the verification, validation, and preliminary quality/usability assessment of chemical analytical data are described below. 6.1 Data verification, validation, and preliminary assessment of data quality and usability shall be conducted in accordance with:  The guidance in EPA QA/G-8, Guidance on Environmental Data Verification and Data Validation, and EPA QA/R-5, EPA Requirements for Quality Assurance Project Plans.  New York State Department of Environmental Conservation (NYSDEC) Division of Environmental Remediation (DER) Guidance for the Development of Data Usability Summary Reports (DUSRs).  Standard operating procedures (SOPs) and guidance for data validation from the EPA Contract Laboratory Program (CLP) and EPA Region 2.  Applicable analytical and sampling methods identified in EPA water and wastewater methods and SW-846. Requirements for these methods in New York State are specified in the NYSDEC Analytical Services Protocol (ASP).  Applicable or pertinent requirements have been integrated into this procedure. 6.2 At a minimum, manual manipulation, handling, and validation of data will be double-checked by the person handling the data. For example, calculations made for particular analytical performance indicators will be double-checked to ensure that they were performed accurately, assigned data qualifiers will be checked to be sure they were assigned correctly, and so on. 6.3 In general, chemical analytical data will be used and reported in the same form and with the same number of significant figures as originally reported by analytical laboratories.

7.0 PROCEDURE 7.1 Chemical Analytical Data Verification and Validation ENV011.01 Page 3 of 4

7.1.1 Assemble the hard-copy data package and original electronic data deliverable (EDD) from the laboratory for the chemical analytical data set. 7.1.2 Assemble the technical scope of work for the laboratory, laboratory SOPs, work plan, SAP, and/or QAPP for the project as well as any applicable regulatory permits or requirements, which together will detail the project objectives, data quality objectives (DQOs) and numeric data quality indicators for the work. 7.1.3 Ensure that the chemical analytical data have been tabulated in a way that allows for clear review, and the assignment of interim and final data qualifiers. 7.1.4 Initiate chemical analytical data verification and validation in accordance with the DUSR template in Attachment 1. Complete the appropriate method-specific checklist in Attachment 1 (e.g., volatile organic compounds [VOCs], general analytical chemistry) for each method reported in the data package. 7.2 Preliminary Chemical Analytical Data Quality Assessment 7.2.1 Following initial data verification and validation, assemble the completed DUSR and method-specific checklists, field information (such as data sheets, field logbooks), and historical project data. If available, also assemble the results of other data assessments such as statistical assessments and comparisons to regulatory standards. Most of those assessments are intended to be performed on validated data (see procedure ENV009) and therefore might not be available. 7.2.2 Review the information to determine whether the chemical analytical data satisfies the original project objectives, DQOs and numeric data quality indicators established for the work. At a minimum, determine whether and how the data satisfy (or do not satisfy) the precision, accuracy (bias), representativeness, completeness and comparability (PARCC) objectives for the project. In many cases, historical data, trends, and expected data ranges can be used to evaluate the representativeness and comparability of the results. Evaluate the sensitivity of the results to verify that the PQLs or LODs are consistent with historical results and project DQOs. 7.2.3 Preliminarily determine whether the data are usable for their intended purpose for the project, and whether the data can be used to make decisions regarding the SDA. Further, investigate data points that are not usable in order to determine whether additional analysis or other examination of the data can improve its usability. (However, note that the process of data verification and validation provides the best opportunity for improving data quality in the time period immediately following data collection and analysis.) 7.3 Reporting on Chemical Analytical Data Verification, Validation, and Quality/Usability 7.3.1 Summarize the results of chemical analytical data verification, validation, and quality/usability assessment in the data report provided to NYSERDA. Ensure that data qualifiers are defined and that qualified data are described and addressed. 7.3.2 Assemble the final verified and validated data into electronic and hard-copy tables per procedure ENV009. ENV011.01 Page 4 of 4

8.0 RECORD KEEPING The project files will include the following documentation:  Electronic and hard copies of data packages and data files provided by chemical analytical laboratories.  Records of adjustments made to analytical data as a result of data verification and validation.  Both hard and electronic copies of reports provided to NYSERDA related to data verification, validation and quality/usability assessment.  A copy of the completed DUSR and method-specific checklists. 9.0 REFERENCES AND BIBLIOGRAPHY 9.1 New York State Department of Environmental Conservation (NYSDEC), 2005, Analytical Services Protocol, Albany, NY. 9.2 ______, 1999, Division of Environmental Remediation (DER) Guidance for the Development of Data Usability Summary Reports (DUSRs), Albany, NY. 9.3 U.S. Environmental Protection Agency (EPA), 2004, Contract Laboratory Program National Functional Guidelines for Inorganic Data Review, OSWER 9240.1-45, EPA 540-R-04-004, Washington, DC. 9.4 ______, 2002, Guidance on Environmental Data Verification and Data Validation, EPA QA/G-8, Washington, DC. 9.5 ______, 2001, EPA Requirements for Quality Assurance Project Plans, EPA QA/R-5, Washington, DC . 9.6 ______, 1999, Contract Laboratory Program National Functional Guidelines for Organic Data Review, EPA-540/R-99-008 (PB99-963506), Washington ,DC. 9.7 EPA Region 2, various dates, SOPs for Evaluation of Metals Data for CLP, HW-6, rev 11, 1/92; TCLP Data Validation, HW-7, rev 3, 3/93; Organic Data Review for Low Conc. Water, HW-13, rev 2, 10/96; and CLP Organic Data Review, HW-15, rev 2, 5/93; New York, NY.

10.0 ATTACHMENT(S) Attachment 1: Data Usability Summary Report (DUSR) Template and Method-Specific Checklists (14 pages)

ATTACHMENT 1

Data Usability Summary Report (DUSR) Template and Method-Specific Checklists

This page intentionally left blank. Attachment 1

Data Usability Summary Report (DUSR) Template and Method-Specific Checklists

Data Usability Summary Report (DUSR) Project: Laboratory: Lab SDG ID: Date Completed: Data Validation Chemist:

Explanation of Work Performed

The samples and analytical methods included in this sample delivery group (SDG) are documented in Table 1, Summary of Samples for this SDG, and Table 2, Summary of Method Tests. The analytical data provided by the laboratory were reviewed for precision, accuracy, and completeness per New York State Department of Environmental Conservation (NYSDEC) Division of Environmental Remediation (DER) Guidance for the Development of Data Usability Summary Reports (DUSRs), June 1999. Data qualification was reviewed and approved by the qualified Data Validation Chemist listed in the heading of this DUSR. The data validation for individual methods is documented on method-specific checklists, which include an evaluation of the following as applicable:  Holding times;  Initial and continuing calibration;  Laboratory blanks;  Field blanks;  Surrogate recoveries (organics only);  MS/MSD samples;  Laboratory control samples (LCSs, same as matrix spike blanks);  Laboratory duplicates;  Field duplicates;  Sample result verification; and  Method-specific QC samples (e.g., GC/MS tunes). Specific criteria for reporting and QC limits were obtained from the method requirements or NYSDEC Analytical Services Protocol (ASP) requirements. Compliance with the QC criteria is documented on the method-specific checklists. Qualifiers were added to the data to provide additional information regarding the datum and/or indicate potential concerns with data usability. Any qualities affecting data usability are listed in the method-specific checklist and summarized below. The representativeness and comparability of the data were evaluated as part of the preliminary data assessment to determine how data usability may be impacted.

Table 1 Summary of Samples for this SDG Work Sample ID Order Matrix Sample ID Lab ID Date Lab QC MS/MSD Corrections

ENV011.01 Page A1 of 14 Attachment 1

Data Usability Summary Report (DUSR) Template and Method-Specific Checklists

Table 2 Summary of Method Tests Work Test No. of Sample Orders Matrix Method Method Name Samples Type

Completeness Review ― General Sample and Batch Information

1. Is the project-specific information available with which to validate the data – i.e., the subcontract, analytical SOW, laboratory SOPs, project QAPP, etc.?

2. Do samples and analyses on COC check against Lab Sample Tracking Form?

3. Did coolers arrive at lab between 2 and 6oC and in good condition as indicated on COC and Cooler Receipt Form?

4. Frequency of field QC samples correct?

Field Duplicate – typically 1/20 samples.

Trip Blank – Every cooler with VOCs (waters only).

Equipment Blank – typically 1/set of samples per day unless dedicated equipment is used.

5. Is appropriate internal custody and tracking documented? 6. Laboratory QC frequency correct?

Method blank and LCS with each batch and one set of MS/MSD per 20 samples. 7. All forms and raw data complete?

8. Case narrative present and complete?

9. Target analyte list and reporting limits match laboratory Statement of Work?

10. Were any samples reanalyzed or diluted?

For any sample reanalysis and dilutions ensure

ENV011.01 Page A2 of 14 Attachment 1

Data Usability Summary Report (DUSR) Template and Method-Specific Checklists

Completeness Review ― General Sample and Batch Information

that only one result per sample and analyte is flagged as reportable. 11. Do the sample results compare to historical trends? Are the sample results within the range of values previously reported?

Summary of Potential Impacts on Data Usability from Method-specific Checklists Major Concerns

Minor Concerns

ENV011.01 Page A3 of 14 Attachment 1

Data Usability Summary Report (DUSR) Template and Method-Specific Checklists

Key: CCV = Continuing calibration verification COC = Chain-of-custody GC = Gas chromatography GC/MS = Gas chromatography/mass spectrometry ICP = Inductively coupled plasma argon spectrometry ICS = Interference check standard ICV = Initial calibration verification NA = Not applicable LCS = Laboratory control sample MS/MSD = Matrix spike/matrix spike duplicate QAPP = Quality assurance project plan QC = Quality control SD = Serial dilution VOCs = Volatile organic compounds

ENV011.01 Page A4 of 14 Attachment 1

Data Usability Summary Report (DUSR) Template and Method-Specific Checklists

General Analytical Chemistry

DATA REVIEW CHECKLIST

Test: Method No.: Ref.: Laboratory: SDG No.:

Data Review Qualifier Yes No NA Code Comment 1. Are test logbooks and/or spreadsheet present? 2. Did dates of preparation and analysis match summary report? Did reported data match summary report?

3. Did holding times meet NYSDEC ASP requirements from verified time of sample receipt? (Holding times for applicable methods are included at the end of this checklist.) If NYSDEC ASP holding times were not met, were the method holding times met? If method holding times were exceeded, then J flag positive results and UJ flag non-detect results. If holding times were grossly exceeded (twice holding time), then J flag positive results and R flag non- detect values.

4. Have annual MDL study results been provided for the method?

5. Are the MDLs and/or PQLs at or below the project required reporting limits? Determine if matrix effects resulted in higher reported limits, and whether sample clean-up procedures can be used for samples in the future. 6. Was the calibration curve correlation coefficient  0.995?

Were at least five points used for the curve? For gravimetric and microbiological GAC tests, ensure the instruments and/or reagents were calibrated per the method. No curves are run for these tests. If samples were not analyzed under acceptable calibration, then the laboratory is not compliant with method requirements. The data reviewer should use professional judgment to determine if associated data should be qualified.

7. Was the raw data transcribed or transferred to the LIMS system correctly? If not, contact the laboratory and request corrected data.

ENV011.01 Page A5 of 14 Attachment 1

Data Usability Summary Report (DUSR) Template and Method-Specific Checklists

Test: Method No.: Ref.: Laboratory: SDG No.:

Data Review Qualifier Yes No NA Code Comment 8. Is date and time of analysis documented on spreadsheet or logbook and imported into LIMS for each sample? Applicable methods: BOD, color, pH, orthophosphate, turbidity, odor, residual chlorine, and ferrous iron. If time of analysis cannot be verified, flag as potentially not meeting holding times. See Item 3. 9. Was the final result calculated correctly from the raw data? Perform a manual calculation to ensure that the result reported matches the result calculated from the raw data. If not, contact the laboratory and request corrected data. 10. Were 100% of manual calculations or manual integrations checked by laboratory? Cross-check 10% of the calculations if full validation is required for this project. 11. Was data review by line management documented? If not, request documentation from the laboratory.

12. Are calibration standards, internal standards, and check standards from independent sources?

13. Initial Calibration Verification (ICV) and/or Laboratory Control Sample (LCS) recoveries within +/-10% or control limits set by the method? If recoveries are out and the compounds were detected in the samples, the laboratory is not compliant with method requirements. Qualify the analytical batch. Positive results are flagged J as estimated if recoveries were out. Non-detect results are flagged UJ as estimated if recoveries were between 50% and 90%. Results are rejected if recoveries were significantly low or significantly high (i.e., more than +/- 50%). If recoveries were high and associated results were non-detect, then laboratory is considered compliant and no data qualification is required.

ENV011.01 Page A6 of 14 Attachment 1

Data Usability Summary Report (DUSR) Template and Method-Specific Checklists

Test: Method No.: Ref.: Laboratory: SDG No.:

Data Review Qualifier Yes No NA Code Comment 14. Laboratory QC frequency one blank and LCS with each batch and one set of MS/MSD or MS/sample duplicate per 20 samples?

If samples were not analyzed at the required frequency, then the laboratory is not compliant with method requirements. The data reviewer should use professional judgment to determine if associated data should be qualified.

15. Calibration Blanks less than PQL?

Method Blanks less than PQL? If no: If sample results are below the PQL but above the MDL, then report the data as non-detect at the PQL. For samples, if results are greater than the PQL but less than the blank level, use professional judgment to determine if the results should be rejected or U flagged at the blank level. If the results are above the blank level but less than 5 times blank level, then report the results flagged J as estimated.

16. MS recoveries within +/-20% or control limits set by the method? If sample concentration greater than 4X the spike concentration, then no data qualification is required. If MS recoveries are out and LCS is compliant, then only qualify the data for the original sample due to matrix. Positive results are flagged J as estimated. Non-detect results are flagged UJ as estimated if recoveries were between 30 and 80%. Non-detect results are rejected if recoveries were less than 30%. If recoveries were very high, then potential method interferences should be investigated and professional judgment used to determine whether to reject positive results. 17. Sample duplicate (laboratory replicate) or MSD relative percent difference (RPD) <20% or within control limits set by the method? If results are less than 5 times the PQL, then the difference in the results should be less than the PQL. If not, qualify the data for the original sample due to matrix. Positive results are flagged J as estimated.

ENV011.01 Page A7 of 14 Attachment 1

Data Usability Summary Report (DUSR) Template and Method-Specific Checklists

Test: Method No.: Ref.: Laboratory: SDG No.:

Data Review Qualifier Yes No NA Code Comment 18. Continuing Calibration Verification (CCV) standards or additional LCS analyzed every 10 samples and at end?

CCV/LCS recoveries within +/-10% or control limits set by the method? If recovery goals were not met, then qualify the samples after the last acceptable CCV the same as noted above for the ICV.

19. Were any samples reanalyzed or diluted?

For any sample reanalyzed or diluted, only one result should be reported. If the laboratory reported multiple results, then indicate the best result to include in the database and final report. 20. Were deviations documented and comments added to case narrative? If the laboratory failed to document potential QC failures, request formal corrective action from the laboratory to ensure method requirements will be met in the future. 21. Are results reasonable for methods and matrix? If results do not compare to historical data or expected results, perform full validation of the raw data. 22. Are field duplicates (waters) within +/- 40% RPD for positive values greater than PQL? If RPD criteria were not met, qualify the sample batch. J flag positive results. If RPD values were grossly exceeded, investigate potential corrective actions in sampling or analytical procedures. 23. Are all data usable?

Major Concerns:

ENV011.01 Page A8 of 14 Attachment 1

Data Usability Summary Report (DUSR) Template and Method-Specific Checklists

Test: Method No.: Ref.: Laboratory: SDG No.:

Data Review Qualifier Yes No NA Code Comment Minor Concerns:

I attest that I have evaluated all data in accordance with this checklist:______(Reviewer/Date)

Holding Times

Holding Time – ASP Holding Time – Method (from verified time of (from date of sample receipt) sampling) Method

24 hours 48 hours Biological Oxygen Demand, 5 Days (BOD5) – Method 405.1 5 days 7 days Total Suspended Solids – Method 160.2

26 days for H2SO4 28 days for H2SO4 Chemical Oxygen Demand – Method 410.4 preserved samples preserved samples Oil & Grease – Method 1664 Nitrogen, Total (as N) – via TKN and nitrate-nitrite analyses TKN – Method 351.2 Nitrate-nitrite – Method 353.3 Phosphorus, Total – Method 365.2

ENV011.01 Page A9 of 14

This page intentionally left blank.

ENV011.01 Page A10 of 14 Attachment 1

Data Usability Summary Report (DUSR) Template and Method-Specific Checklists

Method 8260 Volatiles

DATA REVIEW CHECKLIST

Test: Method No.: Ref.: Laboratory: SDG No.:

Data Review Qualifier Yes No NA Code Comment 1. Are test logbooks and/or spreadsheet present? 2. Are quantitation reports, chromatograms, and calibration summaries present? 3. Did dates of analysis match summary report? Did reported data match summary report? 4. Did holding times meet NYSDEC ASP requirements from verified time of sample receipt – 5 days? If NYSDEC ASP holding times were not met, was the method holding time of 7 days met? If method holding times were exceeded, then J flag positive results and UJ flag non-detect results. If holding times were grossly exceeded (twice holding time), then J flag positive results and R flag non- detect values. 5. Were 100% of manual calculations or manual integrations checked by laboratory? Cross-check 10% of the calculations if full validation is required for this project. 6. Have the annual MDL study results been provided for the method? If one MDL study is applicable for multiple instruments of the same make and model, was the low standard check received? 7. Are the MDLs and/or PQLs at or below the project required reporting limits? Determine if matrix effects resulted in higher reported limits, and whether sample clean-up procedures can be used for samples in the future. 8. Are all results for method, trip, and/or field blanks below the PQLs?

If no, then: For samples, if results are <5 times the blank or < 10 times blank for common laboratory contaminants then U flag the data. Qualification also applies to TICs. If sample results are below the PQL then report the data as non-detect at the PQL. If the results are above the PQL, then report the results with that numeric value as a non-detect. The data effectively has an elevated PQL. 9. Are calibration standards, internal standards, and check standards from independent sources?

ENV011.01 Page A11 of 14 Attachment 1

Data Usability Summary Report (DUSR) Template and Method-Specific Checklists

Test: Method No.: Ref.: Laboratory: SDG No.:

Data Review Qualifier Yes No NA Code Comment 10. Surrogate recoveries for method blanks and LCS within 70 to 130% or limits established by the laboratory? Surrogate recoveries for samples and MS/MSD within 70 to 130% or limits established by the laboratory?

If no, then samples should be reanalyzed to establish matrix effects. If samples were not reanalyzed or method blank or LCS samples had poor surrogate recoveries, then the laboratory is not compliant with method requirements. Positive results are flagged J as estimated. Non-detect results are flagged UJ as estimated if surrogate recoveries were between 10 and 70%. Non-detect results are rejected if recoveries were less than 10%. 11. Do internal standards (IS) areas and retention times meet criteria? IS areas should be between 50% and 200% of the area of the midpoint calibration analysis.

If no, samples should be reanalyzed to establish matrix effects. If samples were not reanalyzed or IS areas were out, then the laboratory is not compliant with method requirements. Positive results are flagged J as estimated. Non-detect results are flagged UJ as estimated if recoveries were between 10 and 50%. Non-detect results are rejected if recoveries were less than 10%. 12. Is initial calibration for positive target compounds <15 percent relative standard deviation (%RSD) or curve fit?

If calibration criteria were not met, then J flag positive compounds in all samples. 13. Is continuing calibration for positive target compounds < 20.5 percent difference (%D) and were minimum response factors of 0.05 achieved for all target compounds?

If calibration criteria were not met, J flag positive compounds in all samples. If minimum response factors were not achieved, then R flag non-detect results and J flag positive results.

ENV011.01 Page A12 of 14 Attachment 1

Data Usability Summary Report (DUSR) Template and Method-Specific Checklists

Test: Method No.: Ref.: Laboratory: SDG No.:

Data Review Qualifier Yes No NA Code Comment 14. LCS recoveries within 70 to 130% or limits established by the laboratory?

If LCS recoveries are out and the compounds were detected in the samples, the laboratory is not compliant with method requirements. Positive results are flagged J as estimated. Non-detect results are flagged UJ as estimated if LCS recoveries were between 10 and 70%. Non-detect results are rejected if recoveries were less than 10%. If LCS recoveries were high and associated results are non- detect, then laboratory is considered compliant and no data qualification is required.

15. Laboratory QC frequency one blank and LCS with each batch and one set of MS/MSD per 20 samples?

If MS/MSD recoveries are out and LCS is compliant, then only qualify the data for the original sample due to matrix. Positive results are flagged J as estimated. Non-detect results are flagged UJ as estimated if MS/MSD recoveries were between 10 and 70%. Non-detect results are rejected if recoveries were less than 10%. 17. MS/MSD relative percent difference (RPD) within 25% or limits established by the laboratory?

If MS/MSD RPDs are out and LCS is compliant, then only qualify the data for the original sample due to matrix. Positive results are flagged J as estimated. 18. Sample duplicate (laboratory replicate) or MSD relative percent difference (RPD) <20% or within control limits set by the method? If results are less than 5 times the PQL, then the difference in the results should be less than the PQL. If not, qualify the data for the original sample due to matrix. Positive results are flagged J as estimated. 19. Were any samples reanalyzed or diluted?

For any sample reanalyzed or diluted, only one result should be reported. If the laboratory reported multiple results, then indicate the best result to include in the database and final report.

ENV011.01 Page A13 of 14 Attachment 1

Data Usability Summary Report (DUSR) Template and Method-Specific Checklists

Test: Method No.: Ref.: Laboratory: SDG No.:

Data Review Qualifier Yes No NA Code Comment 20. Were deviations documented and comments added to case narrative? If the laboratory failed to document potential QC failures, request formal corrective action from the laboratory to ensure method requirements will be met in the future. 21. Are results reasonable for methods and matrix? If results do not compare to historical data or expected results, perform full validation of the raw data. 22. Are field duplicates within +/- 40% RPD for positive values greater than PQL? If RPD criteria were not met, J flag positive results. If RPD values were grossly exceeded, investigate potential corrective actions in sampling or analytical procedures. 23. Are all data usable?

Major Concerns:

Minor Concerns:

I attest that I have evaluated all data in accordance with this checklist:______(Reviewer/Date)

ENV011.01 Page A14 of 14

Surface Water Sampling ENV013.02

Prepared by: Jean L. Williams

New York State Energy Research and Development Authority West Valley Site Management Program

West Valley, NY

05-09-2019

This page intentionally left blank.

1 Purpose

This procedure establishes the methods to be used for collecting surface water samples from streams, seeps, or other surface water bodies for four locations adjacent to, and two locations away from, the New York State Energy Research and Development Authority (NYSERDA) State-Licensed Radioactive Waste Disposal Area (SDA). The SDA is a management area consisting of:

• an acre landfill containing radioactive and hazardous wastes in 14 disposal trenches • three closed and filled lagoons • the T-1 Building (providing weather protection for temporary storage [i.e., < 90 days] of small amounts of low-level radioactive waste and/or mixed low-level radioactive waste) • the Frac Tank Building (containing never-used frac tanks and storage facilities for both clean supplies and solid low-level radioactive waste and industrial wastes generated from SDA activities) This procedure could be used to conduct any surface water sampling at or near the SDA, pending information on the location and analytical parameters of interest.

2 Scope

This procedure: • defines the methods for sampling surface water for radiological constituents • describes requirements for sample containers, volumes, and field quality control (QC) samples • defines the methods for field documentation, sample identification, and labeling This procedure does not address sample custody, packaging, and transport, which are addressed in other West Valley Site Management Program plans and procedures.

3 Responsibilities

3.1 The NYSERDA Project Manager

The NYSERDA Project Manager is responsible for: • coordinating with the Environmental Monitoring Contractor to schedule surface water sampling field work • ensuring timely receipt of data and requisite paperwork from the contractor • reviewing completed reports and electronic deliverables for accuracy • maintaining the proper documentation in the West Valley Site Management Program central files

Surface Water Sampling, ENV013.02 1 • notifying the SDA and Retained Premises Program Manager when problems or trends in the data are identified • providing accurate information on surface water data and trends for inclusion in NYSERDA annual and quarterly reports to the regulator • following up on safety issues raised by field personnel to ensure that corrective actions are being taken, and the appropriate West Valley Site Management Program staff are being notified and involved in corrective action plans or resolutions • responding to Contactor inquiries and providing field support as needed

3.2 The Environmental Monitoring Contractor

The Environmental Monitoring Contractor is responsible for:

• providing trained and qualified personnel to conduct environmental surface water sampling in compliance with this procedure • coordinating all activities with the NYSERDA Project Manager • obtaining certified precleaned sample containers (prepreserved for samples to be evaluated for gross alpha and gross beta) to be available for surface water sampling • providing coolers or boxes (to carry samples and sample bottles), disposable gloves or paper towels, sample labels, etc. for surface water sampling activities • completing accurate entries in the Surface Water Sampling Log and field logbook(s) • preparing and shipping surface water samples to the vendor laboratory for analysis in accordance with applicable NYSERDA plans and procedures • providing recommendations to the project manager for any changes needed to this procedure • promptly notifying the NYSERDA Project Manager or designee of developing issues/problems or off-normal events • providing NYSERDA with an accurate and defensible report once data is available

4 Quality Requirements

This section contains the key quality requirements applicable to the field collection of surface water samples. The surface water monitoring program shall be conducted in accordance with the guidance, requirements, and/or analytical methods identified in:

• Multi-Agency Radiological Laboratory Analytical Protocols Manual1 • HASL-300, the Procedures Manual of The Environmental Measurements Laboratory2 • SW-846, Test Methods for Evaluating Solid Waste, Physical/Chemical Methods3 • Specifications and Guidance for Contaminant-Free Sample Containers4 Applicable or pertinent requirements of these documents have been integrated into this procedure.

Surface water samples shall be collected from predetermined locations using certified precleaned sample

Surface Water Sampling, ENV013.02 2 containers. In addition, bottles used for the collection of samples to be analyzed for gross alpha and gross beta shall be prepreserved by the laboratory prior to sample collection.

A field duplicate QC sample shall be collected to measure and assess field precision (reproducibility). The field duplicate is collected on two alternating quarters during the calendar year in the same location, at the same time, and in the same manner as the original field sample. This field duplicate will be submitted for the full suite of analyses. The location selected for field duplicate sampling should be varied between sampling rounds.

A matrix spike/matrix spike duplicate (MS/MSD) field and analytical QC sample shall be collected for tritium analysis at least once during the calendar year or as requested for other isotopes. The MS/MSD is used to measure and assess the effects of the sample matrix on analytical accuracy and precision. MS/MSD sample volumes collected in the field are spiked in the laboratory with known quantities of target analytes. The recoveries of the analytes in the MS and MSD samples are assessed to determine accuracy, and the relative quantities of the analytes between the MS and MSD samples are assessed to determine precision.

An analytical QC will also be performed using a laboratory replicate to measure and assess primarily analytical precision (reproducibility). A laboratory replicate will be taken from the original field sample by the analytical laboratory, therefore additional volume is not required.

1 Multi-Agency Radiological Laboratory Analytical Protocols Manual (MARLAP), Washington DC, U.S. Nuclear Regulatory 2004. 2 HASL-300, Procedures Manual of The Environmental Measurements Laboratory, DHS, 1997. 3 SW-846, Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, U.S. Environmental Protections Agency, 2014. 4 EPA/540/R-93/051, Specifications and Guidance for Contaminant-Free Sample Containers, U.S. Environmental Protections Agency, 1992.

5 Procedure

SDA surface water is monitored at four locations in stream channels bordering the SDA (i.e., WNDCELD, WNFRC67, WNERB53, and WNNDADR). In addition, one set of samples is collected at a background location (WFBCBKG) to track ambient surface water concentrations for the same parameters monitored at the SDA surface water locations. One annual sample is also collected at a location (WFBCANL) downstream of where SDA-influenced groundwater daylights to become part of Buttermilk Creek surface water. Samples shall be collected from each location for gross alpha, gross beta, and tritium analyses.

Surface Water Sampling, ENV013.02 3 When field conditions require deviation from the predetermined location due to low flow conditions or other circumstances, the contractor shall choose a nearby location within the flow channel, or one that is representative of the drainage and collection environment intended by that surface water location. The contractor shall ensure that the surface water samples are not collected downstream from, or at a location influenced by. discharges from other flow channels or effluent; for example, ensure that the surface water samples collected at location WNDCELD are collected upstream of SDA Stormwater Outfall W05.

5.1 Collecting a Grab Surface Water Sample

The steps described in this procedure shall be used to collect surface water grab samples at designated surface water monitoring locations. The table in Attachment B, SDA Surface Water Sampling and Analysis Summary, shows the sampling and analysis summary for these six routine surface water samples, including required analyses, container types, QC samples, sample volumes, and preservatives (provided in prepreserved bottles).

5.1.1 Location

Verify the proper sample location by referring to Attachment A and the location marker. The sample location IDs are:

• WNDCELD – Franks Creek, located south of the SDA and the Drum Cell – monitors drainage upstream of the SDA outfalls. This area can be accessed via the schoolhouse gate or the south SDA mangate. • WNFRC67 - Franks Creek, located east of the SDA, just upstream of the plunge pool, downstream of the Drum Cell area - monitors drainage from the eastern and southern outfalls within the SDA. This location may be accessed via the SDA Buffer Area Gate at the east side of the SDA. • WNERB53 - Erdman Brook, located north of the SDA and NDA near the terminus of the armored swale on the north slope of the SDA - monitors the combined drainage from the SDA and NDA. This location can be accessed via a WVDP access road on the North Plateau. • WNNDADR - Lagoon Road Creek and the ditch between the NDA and the northwest slope of the SDA - monitors drainage from both areas. This location can be accessed via stairs north of the NDA. The water beneath the auto-sampler hut has been used as an alternate location if the primary location is too dry or frozen. • WFBCBKG - A background location approximately 1.2 miles southeast (upstream) of the SDA on Buttermilk Creek, just north of the creek’s intersection with Fox Valley Road – monitors ambient surface water concentrations prior to influence by either the SDA or WVDP. Anywhere in the vicinity of the sample pump shed is acceptable if access is difficult at the marked location.

Surface Water Sampling, ENV013.02 4 • WFBCANL – An annual sampling location, approximately 1.5 miles north of the SDA on Buttermilk Creek – monitors surface water downstream of where SDA-influenced groundwater daylights to become part of Buttermilk Creek surface water. Sample in the vicinity of where the railroad bridge crosses over Buttermilk Creek. Figures 1 and 2 in Attachment A: Maps of SDA Surface Water Monitoring Locations show the locations of designated surface water sampling points: Figure 1 shows the four near-SDA surface water sampling locations (WNDCELD, WNFRC67, WNERB53, and WNNDADR); while Figure 2 shows the two additional surface water sampling points located away from the SDA (WFBCBKG and WFBCANL).

5.1.2 Sample Collection

The Environmental Contractor shall collect samples at each of the designated locations as described in this section.

5.1.2.1 Don disposable gloves, which are to be worn for all sampling activities and changed between sample locations to prevent any possibility of cross-contamination.

5.1.2.2 Collect representative samples from the center of flow of the stream (if possible), by immersing the unpreserved, precleaned sample container in the water (or hold the container under the water flow) until completely full, transferring the samples for gross alpha and gross beta analysis to the appropriate prepreserved bottles and then collecting the unpreserved sample for tritium analysis. Be careful to avoid disturbance of stream sediment or impoundment substrate while collecting the sample and displacement of the preservative from a prepreserved sample container when transferring liquid. Tightly cap the sample container and ensure that the cap is not cross-threaded with the bottle. Wipe off excess water.

5.1.2.3 Identify the sample by marking the sample location ID on the bottle using permanent marker or by affixing the sample label to the bottle. Sample labeling is discussed in Section 5.1.3 Sample Identification and Labeling.

5.1.2.4 Repeat the process for all sample parameters and for all required sample locations as specified in Attachment B.

5.1.2.5 Collect the field duplicate sample (on alternating calendar quarters) at a location with sufficient volume in the same manner as the original sample before moving on to the next location.

5.1.2.6 Collect the field MS/MSD sample fractions for tritium analysis (at least once per calendar year) at a location with sufficient volume. Collect the MS/MSD sample fractions in in the same manner as the

Surface Water Sampling, ENV013.02 5 original fractions collected for tritium analysis before moving on to the next location.

5.1.2.7 Document sample collection per Section 5.1.4 Field Documentation.

5.1.3 Sample Identification and Labeling

5.1.3.1 Sample Identification (Sample ID)

Assign a unique Sample ID to each sample using the convention, xxxx-60yzz, where:

• xxxx = calendar year • 60 = fixed code signifying a surface water sample ID • y = calendar quarter (1, 2, 3, or 4) • zz = sequential number (01 and up) Assign the field duplicate sample its own unique Sample ID. MS/MSD sample fractions are not assigned a unique Sample ID.

5.1.3.2 Sample Labeling

Identify each sample with a sample label that includes the following information:

• Sample ID • Sample Location ID • sampler name • collection date and time • analyses required • preservative used • identification of the sample as an MS/MSD sample (when applicable)

5.1.3.3 Cover the completed sample label with clear tape.

5.1.3.4 Tape the sample lid (using electrical tape or clear tape) to prevent leaks.

5.1.4 Field Documentation

Double-check the collection and recording of the field data each step of the way to ensure accurate documentation. Further review the work before leaving the site.

Complete the Surface Water Sampling Log for each surface water location sampled. Record field QC samples collected at that location. The logs will be a permanent part of the field records and will be maintained with the field logbooks.

Surface Water Sampling, ENV013.02 6 Document sampling activities in the field logbook for surface water monitoring. Reference in the logbook any forms or data sheets used to record field information (e.g., Surface Water Sampling Log). The information on those forms and data sheets does not have to be duplicated in the logbook.

Make corrections to field documentation by drawing a single line through the original entry (so that the original entry can still be read) and writing the corrected entry alongside. Corrections must be initialed and dated.

6 Attachments

6.1 Attachment A, Maps of SDA Surface Water Monitoring Locations (two pages).

6.2 Attachment B, SDA Surface Water Sampling and Analysis Summary (one page).

Surface Water Sampling, ENV013.02 7

This page intentionally left blank.

Attachment A – Maps of SDA Surface Water Monitoring Locations

Figure 1. Surface Water Monitoring Locations near the SDA

Source: NYSERDA

Surface Water Sampling, ENV013.02 A1 Attachment A – Maps of SDA Surface Water Monitoring Locations

Figure 2. Background and Annual Surface Water Monitoring Locations

Source: NYSERDA

Surface Water Sampling, ENV013.02 A2 Attachment B – SDA Surface Water Sampling and Analysis Summary

Source NYSERDA

Field QC Samples Size and Required Sample Volume (mL) Maximum Parameter Field Type of Preservative MS MSD Ideal Minimum Holding Time Duplicate Container Quarterly Surface Water Samples 2/year; Gross Alpha alternating − − 1-L poly 500 200 HNO3 6 months quarters 2/year; Gross Beta alternating − − 1-L poly 500 200 HNO3 6 months quarters 2/year; 250-mL Tritium alternating 1/year 1/year 100 50 None 6 months glass quarters Annual Surface Water Samples Gross Alpha 1 every 2 years 1-L poly 500 200 HNO3 6 months Gross Beta 1 every 2 years 1-L poly 500 200 HNO3 6 months 250-mL Tritium 1 every 2 years 100 50 None 6 months glass Nonroutine Surface Water Samples Gamma As specified − − 1-L poly 2000 500 HNO3 6 months Spectroscopy Isotopic Analysis As specified As specified As specified TBDe TBD TBD TBD TBD

e To Be Determined (TBD)

Surface Water Sampling, ENV013.02 B1

This page intentionally left blank.

West Valley Site Management Program Page 1 of 24 ENVIRONMENTAL MONITORING PROCEDURE 06/29/2010

TITLE: Stormwater Sampling ENV014.00

1.0 PURPOSE

This procedure establishes the methods to be used for collecting semiannual stormwater samples from outfalls located at the State-Licensed Disposal Area (SDA), in compliance with the State Pollutant Discharge Elimination System (SPDES) Stormwater Monitoring permit.

2.0 SCOPE

This procedure describes the:

• Methods for sampling stormwater for chemical, biological and radiological constituents. • Requirements for sample containers, sample volumes, preservatives and field quality control (QC) samples. • Methods for sample identification and labeling, and field documentation. • Minimum health and safety requirements for the work.

This procedure does not address sample custody, packaging, and transport, which are addressed in procedure ENV008, Field Sample Management.

3.0 EQUIPMENT AND SUPPLIES

Flow Measurement — Permanently installed staff gauges at monitored outfall locations and sturdy folding ruler (as backup for, or to check, staff gauges).

pH Measurement — YSI 556 Multi Parameter System (MPS) or equivalent water quality meter, pH calibration standards, dedicated pH measuring cup, plastic buckets (at least four) and Water Quality Calibration Log (Attachment 1).

Sampling and Compositing — Sample containers (certified pre-cleaned), graduated cylinders (10-mL, 100-mL, and 1,000-mL), poly beakers (5,000-mL), analyte-free deionized (DI) water, bottled drinking water or tap water, disposable gloves, paper towels, coolers (to carry sample bottles and samples), sample preservatives, ice, laptop computer, spreadsheet for flow determination and sample compositing, hard- copy flow graphs and calculator.

Sample Identification and Field and In-House Documentation — Sample labels, Stormwater Sampling Log (Attachment 2), field logbook and weather tracking records.

4.0 DEFINITIONS

Field Blank Sample — A field QC sample collected to measure and assess potential sources of sample contamination and bias. For this procedure, the field blank will be a combined bottle blank and field blank that will assess potential contamination from the sample bottles, and from transport, storage and field handling practices.

ENV014.00 Page 2 of 24

Field Duplicate Sample — A field and analytical QC sample collected to measure and assess field and analytical precision (reproducibility). The field duplicate is collected in the same location, at the same time, and in the same manner as the original field sample.

First flush Grab Sample — A sample collected from the outfall within the first 30 minutes (or as soon thereafter as practicable) of the discharge.

Flow-Weighted Composite Sample — A sample formed by combining calculated proportional volumes from time-aliquots collected at specific timed intervals over the duration of a three-hour storm event. Time-aliquots from periods of higher flow (discharge) will contribute more to the composite sample than time-aliquots from periods of lower flow.

Laboratory Replicate Sample — An analytical QC sample primarily used to measure and assess analytical precision (reproducibility). The laboratory replicate is typically split off of the original field sample by the analytical laboratory. To ensure that the laboratory has enough sample to perform laboratory replicate (sometimes called laboratory duplicate or matrix duplicate) analyses, extra sample volume will typically be collected in the field by the sample team and allocated for laboratory replicate analysis.

Matrix Spike/Matrix Spike Duplicate Sample — A field and analytical QC sample collected to measure and assess the effects of the sample matrix on analytical accuracy and precision. MS/MSD sample volumes collected in the field are spiked in the laboratory with known quantities of target analytes. The recoveries of the analytes in the MS and MSD samples are assessed to determine accuracy, and the relative quantities of the analytes between the MS and MSD samples are assessed to determine precision.

Qualifying Storm Event — A storm qualifies for stormwater sampling if:

• Rainfall is greater than 0.1 inches; • It is preceded by at least 72 hours since the last measurable (>0.1 inches rainfall) storm event; and • Where feasible, the variance in the duration of the event and the total rainfall of the event should not exceed 50% from the average or median rainfall event in that area. Until further notice, the average rainfall event for this area will be 0.42 inches (as documented in the most recent West Valley Demonstration Project [WVDP] Annual Environmental Report).

To ensure that stormwater is sampled during each semiannual period and that data reports meet the reporting schedule required by the SDA Stormwater permit, if a qualifying storm event is not sampled in the first three months of a semiannual period, the next significant rain event (>0.1 inches) will be sampled. To the extent practicable, NYSERDA prefers that the outfall is dry before such an event starts and is sampled. In addition, NYSERDA requires that there be no measurable snow accumulation in the outfall drainage area at the time of sampling so that the samples are not affected by recent snow melt. Results for samples collected during storm events that ultimately do not meet the above criteria will be reported and accompanied by an explanation (e.g., storm duration was too short).

State-Licensed Disposal Area (SDA) — A management area consisting of:

• A 15-acre landfill containing radioactive and hazardous wastes in 14 disposal trenches.

ENV014.00 Page 3 of 24

• Three closed and filled lagoons. • The Tank T-1 Building, which was previously used for storage of 8,000 gallons of Trench 14 leachate that was removed during 2009 and 2010. • The Frac Tank Building, containing never-used frac tanks and storage facilities for both clean supplies and solid wastes generated from SDA activities (nonradiological solid wastes only).

Temperature Blank — A field QC sample prepared to track and measure the temperature at which collected samples are maintained during on-site storage and transportation to the laboratory.

Time-Aliquot — The stormwater sample fractions collected at 20-minute intervals for use in composing the flow-weighted composite sample. For example, the time-aliquots collected at the first 20-minute interval of the sampling period would be designated as time-aliquot 1; the time-aliquots collected at the next 20-minute sampling interval would be designated as time-aliquot 2; and so on.

Volume-Aliquot — The proportional volumes drawn from each time-aliquot to make the final flow- weighted composite sample.

5.0 HEALTH AND SAFETY

Personnel who perform stormwater sampling at the SDA must be aware of the potential hazards associated with this work and follow the controls, limitations, and precautions specified in the training materials and safety documentation below to minimize the potential for injury or illness while conducting work activities:

$ Radiation Worker Training (minimum level I) $ HAS005, (WVSMP) Site-Specific Training Manual for the SDA $ Contractor Site-Specific Health and Safety Plan $ ENV014, Stormwater Sampling procedure

Staff must complete required training at least annually and complete the WVSMP Safety Training Acknowledgment for Contractor Staff Performing Stormwater Sampling at the SDA (Attachment 4). Completed acknowledgments must be returned to NYSERDA at least two days prior to performing the work.

6.0 QUALITY REQUIREMENTS

The key quality requirements applicable to the field collection of the stormwater samples are described below.

6.1 The Stormwater Monitoring Program shall be conducted in accordance with:

$ NYSDEC No. 9-0422-00011/02001, SPDES No. NY-0269271 (SPDES permit). $ EPA Form 2F requirements and NPDES Stormwater Sampling Guidance, EPA 833-B- 92-001 (July 1992). $ Applicable guidance in the Multi-agency Radiological Laboratory Analytical Protocols Manual (MARLAP manual), EPA QA/G-8, Guidance on Environmental Data

ENV014.00 Page 4 of 24

Verification and Data Validation, and EPA QA/R-5, EPA Requirements for Quality Assurance Project Plans. $ EPA-approved analytical methods in 40 CFR 136 and applicable methods in HASL-300, SW-846, and EPA 900-series water methods.

Applicable or pertinent requirements from these documents have been integrated into this procedure.

6.2 Field QC samples will include:

Field Duplicates — collected during each sampling event of either the grab sample or the composite sample and submitted for the full suite of analyses. The type of field duplicate (i.e., grab vs. composite) should be alternated each semiannual round, as feasible.

Field Blanks — collected during each sampling event of either the grab sample or the composite sample and submitted for the full suite of analyses. The type of field blank (i.e., grab vs. composite) should be alternated each semiannual round as feasible.

Matrix Spike/Matrix Spike Duplicates (MS/MSD) — collected for specified parameters (e.g., oil and grease, tritium) of either the grab sample or composite sample at least once during the calendar year. The type of MS/MSD (i.e., grab vs. composite) should be alternated each time collected as feasible.

Laboratory Replicates — extra volume collected during each sampling event for specified parameters to ensure that the laboratory has enough sample to perform laboratory replicate analyses. For the chemical analyses, laboratory replicate analyses are typically performed when MS/MSD analyses are not. For the radioactive analyses, laboratory replicate analyses are typically performed regardless of whether MS/MSD analyses are performed.

Temperature Blanks — prepared for each cooler of samples, required to be cooled to 4ΕC during on- site storage and off-site transportation to the laboratory.

Specific requirements for field QC samples are described in Section 7.

6.3 Certified pre-cleaned sample containers will be used.

7.0 PROCEDURE

The following steps will be used to collect stormwater samples at SDA Outfall W01 (preferred collection location), or an alternate location such as W03 or W04 (see Figure 7-1). Stormwater samples will be collected semiannually during a qualifying storm event. The specified semiannual periods are January 1 to June 30, and July 1 to December 31. In order to accommodate analytical turnaround times and the 28- day reporting deadline to NYSDEC, sampling events should be completed for the first semiannual period no later than the third week of May, and for the second semiannual period no later than the third week of November.

ENV014.00 Page 5 of 24

7.1 Storm Event Monitoring

Obtain storm event data and information from an appropriate meteorological measurement station nearest to the SDA. The station selected must provide storm event data representative of conditions at the SDA and be suitable for forecasting storm events and determining if a qualifying storm event has occurred. Methods and potential sources for monitoring storm events consist of:

• Neighborhood WeatherBug stations located approximately two miles south of the Western New York Nuclear Service Center (WNYNSC) at West Valley Central School and approximately four miles north of the WNYNSC at Springville Middle School. http://weather.weatherbug.com (zip code 14171). • National Weather Service Forecast Office (NOAA) - http://www.noaa.gov (zip code 14171). • Local/cable news stations. • The WVDP or NYSERDA meteorological station at the WNYNSC, which are the closest and most representative of conditions at the SDA. NYSERDA’s contractors are on the notification list to receive stormwater monitoring and storm event updates (e.g., rainfall amount, duration, and end of the minimum 72-hour period) for the SDA. Additionally, the WVDP environmental contractor can be contacted to confirm storm event and weather conditions.

7.1.2 Evaluate weather conditions and forecasts daily or as frequently as necessary to determine potential sampling dates and times in compliance with the conditions for a qualifying storm event as defined in Section 4. After the third month of a semiannual period, identify storm events that will likely result in >0.1 inch of rainfall.

7.1.3 Download and maintain weather forecast and data reports as necessary to determine and document qualifying and non-qualifying storm events.

7.2 Pre-Sampling Preparation

Due to the need to deploy for stormwater sampling with short notice, the following steps will be used to ensure readiness.

7.2.1 The field team will operate in an on-call mode during the week(s) of anticipated potential sampling, having all necessary field equipment (e.g., bottles, preservatives, coolers, paperwork, laptop computer, field clothes) readily available.

7.2.2 Assemble the required number of sample bottles needed to collect the first flush grab sample, the time-aliquots for the flow-weighted composite sample, and the flow-weighted composite sample itself. Table 7-1 shows the sampling and analysis summary for the SDA stormwater samples, including required analyses, container types, QC samples, sample volumes and preservatives.

For the time-aliquots for the flow-weighted composite sample, four one-liter plastic bottles and one 250-mL glass bottle for each time-aliquot should be sufficient. The total

ENV014.00 Page 6 of 24

number of bottles needed per time-aliquot may be revised based on laboratory volume requirements and field observations. For a three-hour sampling event, roughly nine time- aliquots will be collected, assuming time-aliquots are collected at 20-minute intervals and the first flush grab sample is collected at time zero.

7.2.3 Mark or label the sets of time-aliquot bottles with the time-aliquot number (1 through 9) and place the bottles in coolers labeled as to the time-aliquots they contain. 7.2.4 Similarly assemble extra bottles needed for field QC samples.

7.2.5 Assemble the time-aliquot bottles, sample bottles, coolers, and graduated cylinders in a secured area of the SDA Frac Tank Building. Apply completed custody seals to boxes and coolers of assembled sample containers and supplies, and ensure that the boxes and coolers are taped securely shut to ensure their integrity when not in use.

7.2.6 Assemble sample preservatives in advance and store them in a secure off-site area (to be determined by the contractor) until ready to deploy for sampling. Sample preservatives may not be stored at the SDA Frac Tank Building except when in use.

7.2.7 Assemble other needed supplies (described in Section 3) and ensure their ready availability.

7.3 Sampling Mobilization, Stop/Start Storm Events and False Starts

7.3.1 Mobilize for sampling in accordance with the following requirements:

$ When weather conditions indicate the likelihood of a qualifying storm event at the SDA during normal working hours, Monday through Friday, approximately 0600 to 1500 hours, and in safe conditions. If an afternoon storm is anticipated, leave the office early enough in the day to effectively complete the sampling event in daylight hours. Sample collection will not be conducted past sunset.

$ Plan enough time to be on site and ready to collect the first flush grab sample during the first 30 minutes (or as soon thereafter as practicable) of the discharge.

$ 72-Hour Time Criterion – during the first 3 months of the seminannual period, do not collect samples within 72 hours of a storm event resulting in more than 0.1 inches of rain (or under unsafe field conditions).

$ If after the first three months of the semiannual period there was not a qualifying storm event (or a qualifying storm event was not successfully sampled), collect samples for any storm event expected to exceed 0.1 inches of rain (i.e., the 72-hour time criterion does not apply) as long as no unsafe field conditions exist at the time of the event. To the extent practicable, NYSERDA prefers that the outfall is dry before such an event starts and is sampled.

7.3.2 Notify the NYSERDA Project Manager (PM) and the WVDP Radiation Protection office of the likelihood of deploying for sampling in a timely manner.

ENV014.00 Page 7 of 24

7.3.3 If the sampling team is mobilized and the storm event turns into a start/stop event or a non-qualifying event (a false start), the sampling team should apply the following guidelines:

7.3.3.1 If inadequate sample volumes due to insufficient outfall flow are collected, then discard the samples and/or aliquots and plan to remobilize for the next qualifying storm event.

7.3.3.2 If adequate sample volumes can be collected, then finish sampling in accordance with this procedure, consult with NYSERDA if possible, and submit the samples for analysis. Data and results will be reported to NYSERDA along with an explanation regarding whether the storm event turned out to be a qualifying or non-qualifying event.

7.4 Instrument and Equipment Calibration, Operation, and Maintenance

7.4.1 General

7.4.1.1 Calibrate, operate, and maintain instruments and equipment in accordance with the manufacturer’s guidelines and recommendations.

7.4.1.2 Inspect field instruments and equipment at least twice daily while in use — once during calibration, or first use, and again before returning instruments/equipment to storage at the end of the day. Record preventive maintenance in the field logbook and/or the instrument-specific calibration sheet, or the reference file.

7.4.1.3 If an instrument does not pass its field calibration or performance check or has been otherwise found to be in need of off-site service, do not use the instrument for reportable measurements unless necessary (e.g., when a backup unit is not immediately available). Flag each measurement made under those circumstances so the measurements can be evaluated later for quality.

7.4.1.4 If an instrument or equipment is in need of off-site service, send it for such service as soon as possible and arrange for a backup unit, as necessary.

7.4.1.5 Maintain instruments, such as the YSI 556, and their calibration standards and supplies in a climate-controlled environment such as the SDA facilities vestibule when not in use.

7.4.2 YSI 556 MPS

7.4.2.1 The following actions should be completed when calibrating the YSI 556 MPS:

• Use pH standards that are no older than approximately six months. New standards are typically obtained semiannually for the groundwater sampling work. Have the previous set of standards available as backup in case of spillage or other problems developing during the sampling event.

ENV014.00 Page 8 of 24

• Obtain and install a new pH probe every one to two years of sampling, in accordance with the manufacturer’s recommendations. This is typically accomplished in conjunction with the groundwater sampling work. • Calibrate using the supplemental guidelines stored with the operating manual. • Record calibration results on the Water Quality Calibration Log (Attachment 1).

7.4.2.2 Transport the YSI probe module in the transport/calibration cup with enough tap water to cover the ends of the sensors to keep them from drying out.

7.4.2.3 Use the probe sensor guard to protect the sensors when they are not used with the flow-through cell.

7.4.2.4 When measuring pH and temperature of a collected sample, operate the instrument in accordance with the operating manual and the supplemental guidelines stored with the manual.

7.4.2.5 Ensure that pH and temperature readings have stabilized before recording them.

7.5 Equipment Decontamination

Ensure that reusable equipment used for stormwater sampling is decontaminated before and after use, and between different samples in accordance with the methods described below.

7.5.1 Rinse the pH and temperature sensors with tap water or analyte-free DI water, or triple rinse with the sample water to be measured, before measuring reportable pH and temperature. (Do not subject the pH sensor to prolonged contact with DI water, which can adversely affect the sensor.)

7.5.2 Rinse the pH measurement cup and rain event collection buckets with analyte-free DI water before using for another measurement. When not in use, store the measurement cups in sealed plastic bags or other suitable storage containers to prevent the accumulation of fugitive dust.

7.5.3 Rinse the graduated cylinders and poly beakers (used to prepare composite samples) with analyte-free DI water before use, as well as after use (if being used for other samples).

7.5.4 Rinse any other reusable equipment and supplies with analyte-free DI water between use for different samples.

7.6 Collecting a Stormwater First Flush Grab Sample and On-Site Rainfall Sample

Refer to Table 7-1 for the sampling and analysis summary for the SDA stormwater samples, including required analyses, container types, QC samples, sample volumes, and preservatives. The stormwater first flush grab sample will be collected from the outfall within the first 30 minutes (or as

ENV014.00 Page 9 of 24

soon thereafter as practicable) of the discharge. The collection devices for the on-site rainfall sample also will be deployed during the same period.

7.6.1 Assemble the sample bottles that have already been set aside (see Section 7.2).

7.6.2 Refer to Section 7.8 for the collection of field QC samples applicable to the grab sampling (the schedule for QC samples is specified in Section 6.2 and Table 7-1).

7.6.3 Place enough ice in each cooler to ensure that the sample fractions requiring cooling will be cooled to below 4 ΕC.

7.6.4 Verify proper sample location by referring to the location map in Figure 7-1. Under normal conditions, Outfall W01 is the preferred sample location. If stormwater flow or conditions at Outfall W01 seem unlikely to result in successful grab and composite sample collection, then inspect conditions at alternate outfalls (W03 and W04 are likely the best candidates) to see if successful sampling can be performed. If so, then proceed to sample the alternate location.

7.6.5 Don disposable gloves (worn for all sampling activities and changed between sample locations, if applicable, to prevent cross-contamination).

7.6.6 Deploy approximately four plastic buckets in the vicinity of the outfall to collect adequate rainfall for pH measurement of the on-site rainfall sample.

7.6.7 Note and record the time that the rain starts and water begins to flow at the outfall.

7.6.8 Using the appropriate pre-cleaned sample containers, collect the first flush grab sample from the center of the outfall flow. Orient the mouth of the container downstream and in such a manner as to minimize the potential for sediment disturbance. Collect sample portions for lighter-than-water parameters (e.g., oil/grease) at the surface, where they would be present.

7.6.9 After collection, tightly cap the sample container, wipe off excess water, and place the container in the cooler of ice.

7.6.10 Identify the sample by marking pertinent information on the bottle using permanent marker or by affixing the sample label to the bottle. Sample labeling is discussed in Section 7.10.

7.6.11 Repeat the process for all analytical parameters specified in Table 7-1 for the first flush grab sample.

7.6.12 Also during the first 30 minutes of the discharge, measure pH and temperature of the outfall flow as follows:

• Use the pH measuring cup to collect a grab sample from the center of the outfall flow.

ENV014.00 Page 10 of 24

• Immerse the pH and temperature sensors of the YSI 556 water quality meter in the sample and measure pH and temperature in accordance with Section 7.4. Measure the pH and temperature of the grab sample three times from the same grab volume or from three aliquots of a single master grab volume (i.e., do not obtain three different grab volumes from the outfall and measure pH and temperature of each). Record the three pH and temperature measurements on the Stormwater Sampling Log (Attachment 2). • In accordance with Section 7.5, decontaminate the sensors and pH measuring cup used for the grab sample, and before measuring pH and temperature of the on-site rainfall sample. • Measure pH and temperature of the on-site rainfall sample when enough rainwater has been accumulated in the plastic collection buckets to fill the pH measuring cup. The pH and temperature of the on-site rainfall sample should be measured within the first 30 minutes of discharge, assuming that enough volume has been collected in the buckets. • Pour enough rainwater from the buckets to fill the pH measuring cup. Rainwater may be composited from several buckets if necessary to fill the cup. Measure pH and temperature of the water in the cup three times using applicable steps in Section 7.6.12. The three measurements should be obtained from the same grab or composited volume, or from three aliquots of a single master grab or composited volume (i.e., do not obtain three different aliquots from three different buckets and measure pH and temperature of each). Record the measurements on the Stormwater Sampling Log (Attachment 2). • During sampling rounds where the field QC is scheduled for the grab sample, measure pH and temperature of the field duplicate and field blank samples in accordance with Section 7.8. • Document the sample collection and pH/temperature measurements per Section 7.11.

7.7 Collecting a Stormwater Flow-Weighted Composite Sample

A stormwater flow-weighted composite sample will be collected during the first 3 hours of the storm event or for the entire event if it lasts less than 3 hours. The composite sample will be composed of flow-weighted aliquots drawn from time-aliquots collected at 20-minute intervals during the sampling period. Refer to Table 7-1 for the sampling and analysis summary.

7.7.1 Collecting Time-Aliquots

7.7.1.1 Assemble the time-aliquot bottles set aside (as per Section 7.2). For a 3-hour event, roughly nine time-aliquots will be collected when 20-minute sampling intervals are employed and depending on how long it takes to collect the grab sample (which affects the start time for collecting the composite time-aliquots).

7.7.1.2 Refer to Section 7.8 for the collection of field QC samples applicable to the composite sampling (the schedule for QC samples is specified in Section 6.2 and Table 7-1). Extra time-aliquot bottles will be required for the field duplicate and MS/MSD samples and laboratory replicate volumes.

7.7.1.3 Place enough ice in each cooler to ensure that the collected aliquots will be cooled to below 4 ΕC.

ENV014.00 Page 11 of 24

7.7.1.4 Ensure that the staff gauge at the outfall is securely situated to accurately measure water depth. If the staff gauge is displaced, use a sturdy folding ruler to measure water depth in the outfall pipe. Figure 7-2 shows the water depth measurement reference point for Outfall W01.

7.7.1.5 Don disposable gloves (worn for all sampling activities and changed between sample locations to prevent cross-contamination).

7.7.1.6 Collect the first time-aliquot immediately after collection of the grab sample (e.g., if the grab sample was collected in the first 8 minutes of the event, then the first time-aliquot could be collected at “time event start + 10 minutes”). The entire stormwater sampling event starts when water starts flowing at the outfall. Collect the time-aliquots by filling the containers from the center of the outfall flow. Orient the mouth of the container downstream and in such a manner as to minimize the potential for sediment disturbance.

7.7.1.7 After collection, tightly cap each container, wipe off excess water, and place the container in the cooler of ice.

7.7.1.8 Record the time at which the time-aliquot was collected and the staff gauge reading for that time-aliquot in tenths of a foot (to the nearest 0.01 foot) in the field log book.

7.7.1.9 Repeat the process for all time-aliquots at 20-minute intervals during the first 3 hours of the storm event or for the entire event if it lasts less than 3 hours.

7.7.2 Calculating Flow and Determining Composite Sample Composition

7.7.2.1 Select the calculation spreadsheet (Excel) corresponding to the outfall sampled. (See Figure 7-3- the cells requiring information entry are highlighted in gray). The spreadsheet will determine the flow-weighted contribution to the composite sample from each time-aliquot on the basis of the calculated rate of discharge and total discharge at each time interval over the duration of the sampling event. The rate of discharge is calculated from the elapsed time, flow depth from the staff gauge measurement, and Manning’s equation which includes stream cross- sectional area and wetted perimeter, slope, and roughness (Manning’s coefficient [n]). The ratio of the calculated flow at each sampled time interval to the total calculated flow for the sampling event is used to calculate the proportional volume of each time-aliquot that will be used to make the final composite sample.

7.7.2.2 Enter in the spreadsheet:

$ Date of sampling (Cell G6). $ Personnel/Affiliation (Cell G7). $ Date and time of composite preparation (Cell G8). $ Start time: the time flow starts at the outfall (cell C18).

ENV014.00 Page 12 of 24

$ Time of collection for each time-aliquot, from field logbook (column C). $ Staff gauge reading, from field logbook (column E). $ Total volume required for analysis of all parameters for each flow-weighted composite sample (including a slight surplus) (cell F/G32). $ Desired total volume for each size of bottle into which the proportional contributions will be placed (cells K14, L14, and M14). The common bottle sizes anticipated to be needed are 1-L poly or glass (which should be entered as 980 mL in the spreadsheet to allow for errors that could occur from repeatedly measuring small volumes from different time-aliquots and adding them to the composite sample bottles) and 250-mL glass (which should be entered as 100 mL in the spreadsheet because that bottle will be used for 100-mL sample sizes). Alternatively, a 5,000-mL poly beaker may be used for sample pre-compositing and the well-mixed contents poured into the sample bottles (enter the total volume for each composite sample (same as cell F/G 32).

The spreadsheet will then calculate:

$ Elapsed time (column D). $ Corrected staff gauge value if a physical offset has been applied due to the position of the staff gauge (column F). $ Discharge rate for each sampling interval in cubic feet per second (CFS) using Manning’s equation (column G). $ Periodic discharge (in gallons) for each time interval (column H). $ Total sampling event discharge (in gallons), i.e., the sum of the periodic discharges (cell F/G31). $ Proportion of the total discharge represented by the discharge at each time interval (column I). $ Total proportional volume (in mL) of the total composite sample volume (required by the laboratories) that should come from the time-aliquot collected at that time interval (column J). $ Volume of that time-aliquot (in mL) needed for each size sample bottle to accomplish this (columns K, L, and M; highlighted yellow in the spreadsheet).

Save the spreadsheet runs to the laptop so they can be downloaded later into the project files.

7.7.2.3 If the laptop computer or the spreadsheet is not operational, use the hard-copy flow curve for the outfall to manually determine proportional volume contributions to the final composite sample from each time-aliquot (See Attachment 3 for outfall W01 flow curve). The determination should proceed as follows:

• Using the proper flow curve, convert staff gauge readings to discharge rates in CFS for each time-aliquot. If the staff gauge was positioned with a physical offset, correct the readings before looking up the discharge rate on the flow curve. Record the results in the field logbook.

ENV014.00 Page 13 of 24

• Calculate and record the periodic discharge (in gallons) between each time- aliquot by multiplying the discharge rate (in CFS) times 60 sec/minute times the minutes since the prior sample was collected. To convert to gallons, multiply that value by 7.480519. • Sum the periodic discharge gallons and record this total discharge volume in gallons in the field logbook. • To calculate the volume needed from each time-aliquot for the final composite sample per bottle size, divide the periodic discharge (in gallons) for each time interval by the total volume discharged during the entire sampling event and multiply that proportion by the total amount needed per bottle size (typically about 980 mL for 1-L glass or poly bottles and 100 mL for 250-mL glass bottles). Record results in the field log book.

7.7.3 Preparing the Flow-Weighted Composite Sample

7.7.3.1 Assemble the pre-cleaned sample containers for the final flow-weighted composite sample. Assemble like-sized bottles together.

7.7.3.2 For the first bottle size, use clean graduated cylinders to measure the volume from time-aliquot 1 that has been determined to proportionally contribute to that bottle size, and add that volume to each bottle. To the extent practicable, use volumes from time-aliquots collected in glass bottles to make up the final samples required to be in glass bottles, and the volumes from time-aliquots collected in poly bottles to make up the final samples required to be in poly bottles. Continue the process for the remaining time-aliquots.

7.7.3.3 Perform the same process for like-sized bottles of a different size.

7.7.3.4 As an alternative to steps 7.7.3.2 and 7.7.3.3, a complete composite sample may be pre-composited in a 5,000-mL poly beaker using the appropriate time-aliquot volumes from the spreadsheet. Mix the pre-composited sample well and pour it into the sample bottles.

7.7.3.5 Tightly cap the sample containers and ensure that the caps are not cross-threaded with the bottles. Wipe off excess water.

7.7.3.6 Affix the proper sample labels to the bottles per Section 7.10.

7.7.3.7 Document the sample preparation per Section 7.11.

7.7.3.8 Retain the time-aliquot volumes until the end of sample preparation in case of error or spillage.

7.8 Collecting and Preparing Field QC Samples

7.8.1 Field Duplicate Sample

ENV014.00 Page 14 of 24

Collect the field duplicate sample in accordance with the schedule and parameters in Section 6.2 and Table 7-1. A field duplicate sample is scheduled to be collected each sampling round and ideally alternated between the grab and composite sample each round.

7.8.1.1 Field Duplicate of First Flush Grab Sample — Collect the field duplicate in direct sequence of, and in the same manner as, the original sample. This also applies to the grab sample volume collected for pH and temperature measurements.

7.8.1.2 Field Duplicate of Flow-Weighted Composite Sample:

• For each time-aliquot collection, attempt to fill at least two extra 1-liter poly bottles (in addition to the bottles already scheduled to be used) to ensure enough volume to prepare both an original and duplicate composite sample. Collect the time-aliquots in the same manner as the original, in accordance with Section 7.7.1. • Use the sample composition determination from Section 7.7.2 to determine the proportional contribution to the field duplicate. This information is the same for both the original sample and the field duplicate. • Prepare the duplicate composite sample from the time-aliquots at the same time the original composite sample is prepared and in accordance with Section 7.7.3.

7.8.2 Field Blank Sample

Collect the field blank sample in accordance with the schedule and parameters in Section 6.2 and Table 7-1. A field blank sample is scheduled to be collected each sampling round and, ideally, alternated between the grab and composite sample each round.

7.8.2.1 Field Blank for First Flush Grab Sample — Collect the field blank using analyte- free DI water and in direct sequence of, and in the same manner as, the original sample. Subject the field blank to the same steps and treatment used when collecting the first flush grab sample. For the field blank for pH and temperature, use bottled drinking water or tap water instead of DI water (which can adversely affect the pH sensor).

7.8.2.2 Field Blank for Flow-Weighted Composite Sample:

• Using analyte-free DI water, fill and handle some “time-aliquot” bottles at the outfall location in approximately the same manner that the stormwater is sampled in accordance with Section 7.7.1. It will not be necessary to fill 4-plus time- aliquot bottles per time interval for the field blank. Instead, fill time-aliquot bottles during the sampling event to with enough DI water to create a final “composite” sample. • Prepare the “composite” field blank by transferring the DI water in the time- aliquot bottles to the final composite sample bottles using the same graduated

ENV014.00 Page 15 of 24

cylinders, equipment, and basic technique as used to create the stormwater composite sample.

7.8.3 MS/MSD Sample

Collect the field MS/MSD sample in accordance with the schedule and parameters in Section 6.2 and Table 7-1. An MS/MSD sample is scheduled to be collected for selected parameters (e.g., oil and grease, tritium) at least once during the calendar year and ideally alternated between the grab and composite sample, as applicable, each time it is collected (note that oil and grease is only collected for the grab sample, so the MS/MSD sample can only be collected for the grab sample).

7.8.3.1 MS/MSD for First flush Grab Sample — Collect the necessary MS/MSD volume in direct sequence of, and in the same manner as, the volume collected for those analyses for the original sample.

7.8.3.2 MS/MSD for Flow-Weighted Composite Sample:

• Determine whether additional bottles need to be filled for each time-aliquot to accommodate scheduled MS/MSD analyses. For example, if extra volume is already being collected for each time-aliquot for other QC samples such as a field duplicate, that extra volume might accommodate the MS/MSD analyses. Collect the time-aliquots in accordance with Section 7.7.1. • Use the sample composition determination from Section 7.7.2 to determine the proportional contribution to the MS/MSD sample. The volume-aliquots needed to prepare MS/MSD samples of specified volume are determined the same way as for the original sample. • Prepare the MS/MSD sample from the time-aliquots at the same time the original composite sample is prepared and in accordance with Section 7.7.3.

7.8.4 Laboratory Replicate Sample Volume

Collect extra volume for field laboratory replicate analyses in accordance with the schedule and parameters in Section 6.2 and Table 7-1. Extra volume is scheduled to be collected each semiannual round for specified parameters to ensure that the laboratory has enough sample to perform laboratory replicate analyses. For the chemical analyses, laboratory replicate analyses are typically performed when MS/MSD analyses are not. Laboratory replicate analyses are typically performed for all radioanalyses regardless of whether MS/MSD analyses are performed.

7.8.4.1 Laboratory Replicate Volume for First flush Grab Sample — Collect applicable extra volume for laboratory replicate analyses in direct sequence of, and in the same manner as, the volume collected for those analyses for the original sample.

7.8.4.2 Laboratory Replicate Volume for Flow-Weighted Composite Sample:

ENV014.00 Page 16 of 24

• Determine whether additional bottles need to be filled for each time-aliquot to accommodate scheduled lab replicate analyses. For example, if extra volume is already being collected for each time-aliquot for other QC samples such as a field duplicate, that extra volume might accommodate the lab replicate analyses. Collect the time-aliquots in accordance with Section 7.7.1. • Use the sample composition determination from Section 7.7.2 to determine the proportional contribution to the laboratory replicate volume. The volume-aliquots needed to assemble lab replicate samples of specified volume are determined the same way as for the original sample. • Prepare the lab replicate volumes from the time-aliquots at the same time the original composite sample is prepared and in accordance with Section 7.7.3.

7.8.5 Temperature Blank Sample

Prepare field temperature blank samples in accordance with the schedule and parameters in Section 6.2 and Table 7-1. Temperature blanks are scheduled to be prepared each sampling round for each cooler of samples holding samples required to be cooled to 4 ΕC during on-site storage and off-site transportation.

7.8.5.1 Prepare each temperature blank by pouring clean water (e.g., tap water, DI water) into a 40-mL VOA vial.

7.8.5.2 Place a temperature blank in each cooler holding samples or time-aliquots requiring cooling and maintain the blank with the cooler throughout the period of sampling, sample handling, and sample management.

7.8.5.3 Following sample compositing and other sample handling and management, include a temperature blank with each cooler of samples during their transport to off-site laboratories.

7.9 Sample Preservation

7.9.1 Precaution — Before preserving samples, don protective apparel and eyewear.

7.9.2 Preserve sample fractions with applicable preservatives as indicated in Table 7-1.

7.9.3 When adding preservative, use a disposable pipet to add preservative to the sample. Rule- of-thumb: approximately 4 to 5 mL of acid should be enough to lower the pH of about one liter of neutral water to <2. Be aware that adding too much preservative will unnecessarily dilute the sample.

7.9.4 Verify the pH of all samples (not just those that have been preserved). To do so, use a clean disposable pipet to collect a drop of sample from the container. Place the drop on pH indicator paper and record the observed pH on both the sample label and the Stormwater Sampling Log (Attachment 2).

ENV014.00 Page 17 of 24

7.10 Sample Identification and Labeling

7.10.1 Assign a unique sample ID to each sample using the following convention:

xxxx-70yzzaaaa Where: xxxx = calendar year 70 = fixed code signifying a stormwater sample ID y = calendar quarter (1, 2, 3, or 4) zz = sequential number for each unique sample (01 and up), e.g., 01 for the first flush grab sample, 02 for the composite sample, 03 for the on-site rainfall sample, 04 for the field duplicate sample, 05 for the field blank sample, and so on aaaa = additional sample identifier as follows:

• “Grab” for first flush grab sample • “Comp” for composite sample • “Rain” for on-site rainfall sample

Assign the field duplicate and field blank samples their own unique sample IDs. To the extent possible, those samples should appear to the laboratory as regular investigative samples. MS/MSD sample fractions and laboratory replicate sample volumes are not assigned a unique sample ID.

7.10.2 Identify each sample with a sample label that includes the following information:

$ Sample ID $ Sample location ID $ Job code $ Collection date and time $ Analyses required $ Preservation used $ Measured pH value $ Whether the sample is an MS/MSD sample or laboratory replicate volume

Sample Location IDs are as follows, including those for outfall locations that might likely be sampled as an alternative to W01. The location IDs follow what has historically been used to identify the location in NYSIMSII.

WNSTM1 = Outfall W01 WNSTM3 = Outfall W03 WNSTM4 = Outfall W04 WNSTM8201 = Field blank

7.10.3 Cover the completed sample label with clear tape.

ENV014.00 Page 18 of 24

7.10.4 Tape the sample lid (using electrical tape or clear tape) to prevent leaks.

7.11 Field Documentation

7.11.1 Double-check the collection and recording of the field data each step of the way with the other member(s) of the field team to ensure accurate documentation. Further review the work before leaving the site.

7.11.2 Complete the Stormwater Sampling Log (Attachment 2) for each location sampled and sample collected, as applicable. Include information for field QC samples. The logs will be a permanent part of the field records and will be maintained with the field logbooks.

7.11.3 Document sampling activities in the stormwater field logbook. Reference any forms or data sheets used to record field information (e.g., Stormwater Sampling Log). The information on those forms and data sheets does not have to be duplicated in the logbook.

7.11.4 Make corrections to field documentation by drawing a single line through the original entry (so that the original entry can still be read) and writing the corrected entry alongside. Corrections must be initialed and dated.

8.0 RECORD KEEPING

Maintain in the WVSMP central files:

$ Original completed Water Quality Calibration Logs $ Original Stormwater Sampling Logs. $ Field Logbook. $ Excel spreadsheet calculations used for each sampling event. $ Backup flow graphs used for each sampling event, as applicable.

9.0 REFERENCES AND BIBLIOGRAPHY

9.1 New York State Department of Environmental Conservation (NYSDEC), 2005, NYSDEC No. 9- 0422-00011/02001, SPDES No. NY-0269271 (SPDES permit), Albany, New York.

9.2 New York State Energy Research and Development Authority, ENV008, Field Sample Management procedure.

9.3 U.S. Environmental Protection Agency (EPA), et al, 2004, Multi-agency Radiological Laboratory Analytical Protocols Manual (MARLAP manual), Washington, DC.

9.4 ______, 2002, Guidance on Environmental Data Verification and Data Validation, EPA QA/G-8, Washington, DC.

ENV014.00 Page 19 of 24

9.5 ______, 2001, EPA Requirements for Quality Assurance Project Plans, EPA QA/R-5, Washington, DC .

9.6 ______, 1992, NPDES Stormwater Sampling Guidance, EPA 833-B-92-001, July 1992, Washington, DC.

10.0 ATTACHMENTS

Attachment 1: Water Quality Calibration Log (one page) Attachment 2: Stormwater Sampling Log (one page) Attachment 3: Flow Conversion Curve for WO1 (one page) Attachment 4: WVSMP Safety Training Acknowledgment for Contractor Staff Performing Stormwater Sampling at the SDA (one page)

ENV014.00 Page 20 of 24

Table 7-1 SDA Stormwater Sampling and Analysis Summary Required Field QC Samples Sample Vol. Size and Ideal Min. Max. No. of Fld Fld Lab Rep Type of Vol. Vol. Hold Parameter Frequency Samples Dup Blk MS MSD Vol Container (mL) (mL) Pres. Time pH and 1 1 temperature (in round when (in round when — outfall field QC is for field QC is for per per a flow Semiannual 1 grab grab sample) grab sample) – – – – meter meter – – pH and temperature — on-site rainfall per per d d event Semiannual 1 – – – – – – meter meter – – 1per year 1 per year (in round Cool to 1 1 (in round when field 1 4°C (in round when (in round when when field QC is for (when 1-L glass field QC is for field QC is for QC is for grab MS/MSD PTFE-lined H2SO4, 28 Oil & Grease Semiannual 1 grab grab sample) grab sample) grab sample) sample) not perf’d) cap 1,000 1,000 pH<2 days Biochemical 1 per yr 1 per yr 1 1 Oxygen (alternate (alternate 1 (collected (collected Demand between grab between (when every round for every round for (BOD) 1 grab and grab and MS/MSD Cool to either grab or either grab or b (5 days) Semiannual 1 composite composite) composite) not perf’d) 1-L plastic 1,000 600 4°C 48 hrs composite; composite; Total alternate every alternate every Suspended 1 grab round, as round, as Cool to b Solids (TSS) Semiannual 1 composite feasible) feasible) – – 1 1-L plastic 500 100 4°C 7 days Cool to Chemical 1 1 1 per yr 1 per yr 1 4°C Oxygen (collected (collected (alternate (alternate (when Demand 1 grab every round for every round for MS/MSD H2SO4, 28 between grab between c (COD) Semiannual 1 composite either grab or either grab or and grab and not perf’d) 1-L plastic 25 5 pH<2 days composite; composite; composite) composite) Cool to Total alternate every alternate every 4°C Kjeldahl round, as round, as

Nitrogen 1 grab feasible) feasible) H2SO4, 28 c (TKN) Semiannual 1 composite 1-L plastic 100 25 pH<2 days

ENV014.00 Page 21 of 24

Required Field QC Samples Sample Vol. Size and Ideal Min. Max. No. of Fld Fld Lab Rep Type of Vol. Vol. Hold Parameter Frequency Samples Dup Blk MS MSD Vol Container (mL) (mL) Pres. Time 1 1 1 per yr 1 per yr 1 Cool to (collected (collected (alternate (alternate (when 4°C every round for every round for between grab between MS/MSD Nitrate- 1 grab H2SO4, 28 either grab or either grab or and grab and not perf’d) c nitrite Semiannual 1 composite 1-L plastic 250 50 pH<2 days composite; composite; composite) composite) alternate every alternate every Cool to round, as round, as 4°C feasible) feasible) Total 1 grab H2SO4, 28 c Phosphorus Semiannual 1 composite 1-L plastic 50 10 pH<2 days

HNO3, e Gross alpha Semiannual 1 composite – – 1 1-L poly 500 200 pH<2 6 mo. 1 1 HNO3, (in round (in round e Gross beta Semiannual 1 composite – – 1 1-L poly 500 200 pH<2 6 mo. when field QC when field QC is for is for 1 per yr 1 per yr composite) composite) (in round (in round when field when field QC is for QC is for 1 250-mL Tritium Semiannual 1 composite composite) composite) glass 100 50 None 6 mo. Gamma Spec (Cs-137, Co- 60, and K-40 at a HNO3, minimum) Semiannual 1 composite – – 1 1-L poly 2,000 500 pH<2 6 mo. a Measured within the first 30 minutes (or as soon thereafter as practicable) for outfall stormwater flow (equivalent to first flush grab sample). b BOD and TSS can go in the same 1-L bottle if only minimum volumes are available. c COD, TKN, nitrate-nitrite, and total phosphorus can go in the same 1-L bottle. d Measured for the on-site rainfall sample (bucket collection method) within the first 30 minutes (or as soon thereafter as practicable) of outfall stormwater flow. e Gross alpha and gross beta total can go in the same 1-L bottle.

Notes: 1. Grab sample is a first flush grab sample collected during the first 30 minutes (or as soon thereafter as practicable) of the discharge. 2. Composite sample is a flow-weighted composite taken for the first 3 hours of the event or for the entire event if it lasts less than three hours. 3. A temperature blank will be prepared and submitted with each cooler of samples required to be cooled to 4 °C. 4. In general, field QC samples will be collected for the grab sample during one semiannual round, and for the composite sample during the other semiannual round

ENV014.00 Page 22 of 24

Figure 7-1 - SDA Stormwater Outfall Map

ENV014.00 Page 23 of 24

Figure 7-2 - Outfall W01 Water Depth Measurement Reference Point

ENV014.00 Page 24 of 24

Figure 7-3 - Example Flow-Weighted Composite Sample Calculation Spreadsheet

Attachment 1

ENV014.00 A-1

Attachment 2: Stormwater Sampling Log

Sample Location ID: Sample Date/Time: Sample ID: ______Sample Type (grab, composite): Field QC Sample Type (Fld Dup, Fld Blank, other): Total Vol. Collected Final Final Lab Required No. of Sample Dup MS/MSD Rep pH per Size and Type Volume Time-Aliq./ Time-Aliq. Vol. Vol. Vol. Vol. verified Parameter of Container Ideal / Min. Pres. Intervl. (mL) (mL) (mL) (mL) (mL) (orig/QC) Chemical Samples — TestAmerica Buffalo Cool to 4°C 1-L glass Oil & Grease PTFE-lined cap 1,000 / 1,000 H2SO4, pH<2

Biochemical Oxygen a Demand (BOD) (5 days) 1-L plastic 1,000 / 600 Cool to 4°C Total Suspended Solids a (TSS) 1-L plastic 500 / 100 Cool to 4°C Cool to 4°C Chemical Oxygen b Demand (COD) 1-L plastic 25 / 5 H2SO4, pH<2 Cool to 4°C Total Kjeldahl Nitrogen b (TKN) 1-L plastic 100 / 25 H2SO4, pH<2 Cool to 4°C b Nitrate-Nitrite 1-L plastic 250 / 50 H2SO4, pH<2 Cool to 4°C

b Total Phosphorous 1-L plastic 50 / 10 H2SO4, pH<2 Rad Samples — GEL c Gross alpha 1-L poly 500 / 200 HNO3, pH<2 c Gross beta 1-L poly 500 / 200 HNO3, pH<2 Tritium 250-mL glass 100 / 50 None Gamma Spec 1-L poly 2,000 / 500 HNO3, pH<2 a BOD and TSS can go in the same 1-L bottle if only minimum volumes are available. b COD, TKN, nitrate-nitrite, and total phosphorus can go in the same 1-L bottle. c Gross alpha and gross beta total can go in the same 1-L bottle. Rdg 1: Rdg 2: Rdg 3:

Time: Time: Time: pH/Temperature Comment: Comments/Observations:

ENV014.00 A-2

Attachment 3

ENV014.00 A-3

This page intentionally left blank.

Attachment 4

WVSMP Safety Training Acknowledgment for Contractor Staff Performing Stormwater Sampling at the SDA

PURPOSE

All personnel involved in this task must complete a review of the documents listed below:

$ ENV014, Stormwater Sampling

• Contractor Site-Specific Health and Safety Plan - Contractor staff shall be familiar with their own site- specific health and safety requirements for performing this work safely at the SDA.

YOUR RESPONSIBILITIES

You must have read/reviewed and understood the documents listed above within the 12 months previous to the performance of this task. If you have any comments or questions regarding this material, please contact the cognizant WVSMP Project Manager or the WVSMP Safety Specialist. Return this signed form to the WVSMP Safety Specialist.

I assert that I have read/reviewed and understood the documents listed above within the last 12 months.

______(Print Name) (Organization/Department) (Badge # )

______(Signature) (Date)

Return this form to:

Jean Williams WVSMP Safety and Health Supervisor 10282 Rock Springs Road West Valley, NY 14171

WVDP mail stop: AC-NYS Telephone: 942-9960 ext. 4092

ENV014.00 A-4

This page intentionally left blank.

Environmental Dosimeter Monitoring at the State-Licensed Disposal Area (SDA) ENV015.03

New York State Energy Research and Development Authority West Valley Site Management Program

West Valley, NY

12/04/2019

This page intentionally left blank.

1 Purpose

This procedure establishes the process by which the West Valley Site Management Program (WVSMP) and its contractors utilize and transport environmental dosimeters that are used to measure ambient gamma radiation levels at the State-Licensed Disposal Area (SDA).

2 Scope

This procedure defines the responsibilities of the Contractor and the New York State Energy Research and Development Authority (NYSERDA) Project Manager (PM) relative to:

• receiving and scheduling of dosimeters • deployment, retrieval, and proper placement of dosimeters in the environment • shipping exposed dosimeters back to the vendor • field documentation • worker health and safety • equipment and supplies • recordkeeping

3 Responsibilities

3.1 Contractor

The Contractor is tasked with the following responsibilities:

• Providing trained and qualified personnel to conduct environmental dosimeter monitoring in compliance with this procedure. • Coordinating all activities (e.g., deployment and retrieval schedule) with the NYSERDA PM. • Coordinating the receipt of dosimeters for each location so that they are available on prescribed deployment dates. • Providing a secure background radiation location for storing the dosimeters until deployment or return to the vendor. • Preparing and returning dosimeters to the vendor for analysis to ensure timely processing and minimize exposure during transit. • Promptly notifying the NYSERDA PM when issues or problems arise. • Ensuring collection and recording of field data is accurate. • Providing NYSERDA with an accurate report including validated analytical data, statistical assessments, and graphs. • Providing NYSERDA with electronic datafiles of the analysis results that are compatible with NYSERDA’s NYSIMS database or equivalent and New York State Department of Environmental Conservation’s EQuIS database.

ENV015.03 1

3.2 NYSERDA Project Manager

• Coordinating with the Contractor for the replacement of environmental dosimeters on a three- month (i.e., quarterly) schedule, including scheduling the date for deployment/retrieval of the dosimeters. • Ensuring timely receipt of contract deliverables for the dosimetry program. • Reviewing completed reports and maintaining the proper documentation in the WVSMP central files. • Preparing data for routine reporting (e.g., SDA Quarterly and Annual reports). • Notifying the WVSMP Radiation Safety Committee when trends or problems are identified, and including data in the WVSMP Radiation Safety Committee ALARA Report, if applicable. • Following up on safety issues raised by field personnel to ensure that corrective actions are being taken, and the appropriate WVSMP staff are being notified and involved in corrective action plans or resolutions. • Responding to Contactor inquiries and providing field support as needed. • Notifying the West Valley Demonstration Project’s (WVDP) dosimetry laboratory of upcoming field deployment activities.

4 Procedure

4.1 Scheduling

Dosimeters will be deployed at each monitoring location for a period of three consecutive months (approximately 91 days). Routine deployment of environmental dosimeters will be scheduled on the working day nearest the fifteenth of the month for each deployment quarter (e.g., March 15 for second quarter, June 15 for third quarter, etc.). The deployment date of dosimeters may be shifted a few days to accommodate scheduled workdays, weather conditions, postal delays or to optimize conditions for dosimeter storage and shipment. The reported results will be normalized to 91 days.

4.1.1 Schedule delivery of the dosimeters from the vendor at least seven days before first working day of the field deployment quarter.

4.1.2 Two weeks prior to deployment, coordinate with the NYSERDA PM or designee regarding the scheduled date of deployment/retrieval.

4.1.3 Two days prior to deployment, confirm with the PM the scheduled date of deployment/retrieval.

NOTE: Deployment and retrieval of dosimeters should be scheduled during normal business hours Monday

ENV015.03 2

through Thursday and so that completion of field activities occurs prior to 14:30 (2:30 PM) to ensure access to the lead cave in the WVDP dosimetry laboratory.

4.2 Receipt of Dosimeters

4.2.1 Upon receipt of the new dosimeters from the vendor, verify the package contains two dosimeters for each field monitoring location, transit control dosimeters and lead cave dosimeters.

4.2.2 Verify that each dosimeter is labeled properly with the following information, and that the packing list matches the dosimeters received. Retain a copy of the bill of lading (if applicable) and the packing list. • a unique dosimeter identification (ID) on each • the dates of the monitoring period of interest (e.g., 03/15 to 06/14 for the second quarter) • location ID (e.g., DNTLD19) See Table 4-1 Dosimeter Identification and Location for a list of location identifications.

4.2.3 Record the following information on the SDA Environmental Dosimeter Deployment/Retrieval Form located in Appendix A: • vendor batch number • monitoring period (e.g., 1Q20) • verify the holder type from the packing list • verify the badge type from the packing list (i.e., UD-814 for Panasonic environmental dosimeters) • vendor supplying dosimeters (i.e., Environmental Dosimeter Company) • the date the vendor shipped the dosimeters • the name of the transport carrier (e.g., United Parcel Service) • the date/time the dosimeter shipment was received • the WVSMP dosimeter identifiers as xxxx-80-y-zzzz Where: xxxx = Calendar year pertinent to the deployment period (e.g., 2020) 80 = Fixed code signifying an environmental dosimeter ID y = Deployment quarter for the year (1, 2, 3, or 4) zzzz = The unique dosimeter ID (from the badges and packing list)

The WVSMP dosimeter ID is the unique identifier by which the dosimeter will be tracked in NYSERDA’s NYSIMS database or equivalent.

Contact the vendor and the NYSERDA PM immediately if any information is incorrect, or any dosimeters are missing and/or mislabeled.

4.2.5 Package the dosimeters in weather resistant badge holders in preparation of field deployment.

ENV015.03 3

4.2.6 Place the dosimeters in a secured location where radiation levels are at natural background levels (e.g., less than or equal to 10 microrem/hour, less than or equal to 60 cpm with an unshielded GM pancake probe) until they are ready to be transported the field for deployment. Record the date/time as a custody entry on the Deployment/Retrieval form (Appendix A).

4.2.7 Note the following changes on the Deployment/Retrieval form:

• when predeployment custody transfers from the recipient of the dosimeters to other recipients • if the predeployment storage location changes Maintain a proper chain of custody for the dosimeters. The dosimeters should be in a secure and documented storage location or the possession of an approved environmental monitoring team member during transport to the site, deployment and retrieval.

4.3 Deployment/Retrieval of Dosimeters

4.3.1 Proper Placement of Dosimeters

Dosimeters will be deployed at the locations described on Table 4-1.

ENV015.03 4

Table 4-1. Dosimeter Identification and Location

Source: NYSERDA

Number of Location ID Monitoring Location Description Dosimeters Background, on the fence along the driveway from Ashford Hollow Road to the Two NYTLDBK Ashford Office Complex Eastern perimeter fence north of SDA buffer area access gate between Two DNTLD19 Survey Points 7 and 8

Outside SDA fence near corner of WVDP perimeter fence and SDA fence. South Two DNTLD33 of SDA Access Gate #15

DNTLD43 Two Western perimeter fence of SDA adjacent to the main SDA Access Gate #15

DNTLD53 Two Northwestern corner perimeter fence of SDA

SDATLD01 Two South fence at approximate center line of Trench 11

SDATLD02 Two East fence middle of southern trenches next to Survey Point 9

SDATLD03 Two East fence middle of northern trenches next to Survey Point 6

SDATLD04 Two North fence approximate center between Trenches 3 and 4

SDATLD05 Two West fence middle of northern trenches next to and south of Survey Point 1

SDATLD06 Two West fence south of Survey Point 15

Transit control dosimeters to accompany the field dosimeters during shipping, NYTLDTC Two deployment and retrieval. Stored in low background storage location for deployment period (e.g., WVDP dosimetry laboratory lead cave).

Lead cave dosimeter deployed in the low background storage location (e.g. Two NYTLDLC WVDP dosimetry laboratory lead cave).

The location of the background dosimeters is depicted in Figure B-1 of Appendix B. The location of the WVDP Dosimetry laboratory is depicted in Figure B-2 of Appendix B. The locations of SDA dosimeters are depicted in Figure B-3 of Appendix B. Location and identification signs are posted at each deployment location.

Deploy the new dosimeters in the exact same location and orientation as the dosimeters being retrieved from the field.

ENV015.03 5

4.3.2 Order of Deployment/Retrieval

4.3.2.1 Obtain the new dosimeters, the new Deployment/Retrieval form, and the Deployment/Retrieval form for the currently deployed dosimeters.

4.3.2.2 Deploy the new background dosimeters (NYTLDBK) first (see Table 4-1, Figure B-1 in Appendix B) and retrieve the previously deployed background dosimeters.

4.3.2.3 Record the date and time of deployment and retrieval on the Deployment/Retrieval forms for both the current and previous quarter’s background dosimeters, respectively. Use the “Comments” section to document any items of note or unusual conditions observed during the exchange process that might affect results. (e.g., dosimeter missing, on the ground, not in assigned location, etc.)

4.3.2.4 Proceed to the site’s low background storage area and place the retrieved background dosimeters (NYTLDBK) in the designated storage location (e.g., lead cave at the WVDP dosimetry laboratory [see Figure B-2]) as temporary storage while the SDA dosimeters are changed out.

4.3.2.5 Collect the previous quarter’s transit control dosimeters (NYTLDTC) and record the date and time of retrieval on the previous quarter’s Deployment/Retrieval forms.

NOTE: All transit control dosimeters should accompany the remaining onsite SDA field dosimeters during deployment and retrieval.

4.3.2.6 Deploy the lead cave dosimeters (NYTLDLC) and record the date and time of deployment for (NYTLDLC) on the current quarter’s Deployment/Retrieval forms.

4.3.2.7 Deploy and retrieve the SDA field dosimeters in accordance with their assigned locations (see Table 4-1, Figure B-3 in Appendix B) and as sequenced on the Deployment/Retrieval form (Appendix A).

4.3.2.8 Record the dates and times of deployment and retrieval on the Deployment/Retrieval forms pertaining to the new and exposed dosimeters, respectively. Use the “Comments” section to document any items of note or unusual conditions observed during the exchange process that might affect results (e.g., dosimeter missing, on ground, not in assigned location, etc.).

ENV015.03 6

4.3.2.9 Return to the low background storage area and place the current quarter’s transit control dosimeters (NYTLDTC) in the designated storage location (e.g., lead cave at the WVDP dosimetry laboratory), and record the date and time as deployed to lead cave storage on the current quarter’s Deployment/Retrieval form.

4.3.2.10 Retrieve the previous quarter’s lead cave dosimeters (NYTLDLC) and record the date and time on the previous quarter’s Deployment/Retrieval form.

4.3.2.11 Retrieve the previous quarter’s background dosimeters. Background retrieval data was previously recorded; see Step 4.3.2.3.

4.3.2.12 Notify the NYSERDA PM immediately if any of the deployed dosimeters are missing from their assigned locations.

4.3.2.13 Document the post-retrieval custody of the dosimeters on the previous quarter’s Deployment/Retrieval form. Document the location of the dosimeters in transit from the site, the post- retrieval storage location prior to return shipment to the vendor, and if and when post-retrieval custody transfers to other recipients. Maintain a chain of custody for the dosimeters. The dosimeters should be in the secure and documented possession of an approved environmental monitoring team member after retrieval and until they are released for return shipment.

4.4 Field Documentation

Double-check the recording of the date and time for collection, and deployment of the field data each step of the way to ensure accurate documentation. Review the work before leaving the site.

4.4.1 Complete the Deployment/Retrieval form as part of field activities. The forms will be a permanent part of the project record and will be maintained with the field logbooks.

4.4.2 Document field activities in the field logbook. Reference any forms or datasheets used to record field information (i.e., the Deployment/Retrieval form). The information on such forms and datasheets does not have to be duplicated in the logbook.

ENV015.03 7

4.4.3 If needed, make corrections to field documentation by drawing a single line through the original entry (so that the original entry can still be read) and writing the corrected entry alongside. Corrections must be initialed and dated.

4.5 Shipment of Dosimeters

4.5.1 Prepare the retrieved dosimeters for shipment to the vendor. Ensure that the dosimeters are packaged securely and protected from damage during shipment, using bubble wrap, if necessary.

4.5.2 Complete the return shipment information on the Deployment/Retrieval form for the retrieved dosimeters.

4.5.3 As soon as practicable following retrieval, ship the dosimeters utilizing a method of shipping that includes tracking numbers and/or a return receipt request. Preferred shipping methods include United Parcel Service and the U.S. Postal Service. The United Parcel Service and the U.S. Postal Service do not handle radioactive material, which minimizes the potential for the badges to be affected by radioactive material during transport.

4.5.4 Retain a copy of the bill of lading (if applicable) and tracking number.

4.5.5 Record the date and time the dosimeters were received by the vendor on the Deployment/Retrieval form. This information will be available from the tracking details, the return-receipt card, and the vendor’s dosimeter report.

5 Quality Requirements

Environmental dosimeter monitoring shall be conducted in accordance with key quality requirements applicable to the deployment and retrieval of environmental dosimeters; these key requirements have been integrated into this procedures as follows:

• Environmental dosimeter monitoring includes the use of transit control dosimeters to measure exposures extraneous to, but integral for, the field measurements of interest. • Two dosimeters will be utilized at each location in order to provide an adequate number of data points for statistical evaluations in the event one is defective or damaged. • Dosimeters will be deployed at consistent predetermined locations and height above the ground, and placed as far away as possible from large or dense objects.

ENV015.03 8 • Dosimeters will be deployed for a period of three consecutive months to achieve an exposure as close as reasonably achievable to 91 days. • The deployment/retrieval form in Appendix A will be utilized as the chain of custody.

6 Health and Safety

Personnel who deploy and retrieve the environmental dosimeters for the WVSMP must be aware of the potential hazards associated with this work. They shall follow the controls, limitations, and precautions specified in the training materials and safety documentation listed below to minimize the potential for injury or illness while conducting work activities:

• Radiation Worker Training (minimum level I) • NYSERDA annual site-specific training • NYSERDA Hazard Identification form and Industrial Work Permit • Contractor Site-Specific Health and Safety Plan Personnel deploying and retrieving dosimeters must complete the requisite training at least annually or as required by the safety documentation.

7 Equipment and Supplies

• Lead cave - Located in the WVDP Dosimetry Department for use as a low-background area for storage of specified dosimeters. • Dosimeters – Minimum of two dosimeters to be used at each field and control location. • Weather Resistant Badge Holders – Heavy duty sealable plastic badge holders for deploying field dosimeters. • Reusable Zip Ties – For securing the field dosimeters at the designated locations. • Field Documentation - SDA Environmental Dosimeter Deployment/Retrieval forms (Appendix A), field logbook, pens, clipboard and SDA Environmental Dosimeter Location figures (Appendix B).

8 Recordkeeping

Maintain the following documentation in the WVSMP central files:

• the original completed Deployment/Retrieval forms • field logbooks • Contractor Environmental Monitoring Reports • vendor laboratory reports

ENV015.03 DRAFT 1 9 9 Appendices

Appendix A - SDA Environmental Dosimeter Deployment/Retrieval form (two pages).

Appendix B - SDA Environmental Dosimeter Location Figures (two pages).

ENV015.03 DRAFT 1 10

Appendix A – SDA Environmental Dosimeter Deployment/Retrieval Form

This page intentionally left blank.

Table A-1. SDA Environmental Dosimeter Deployment/Retrieval Form1

Source: NYSERDA

Batch No.: Monitoring Period: Holder Type: Badge Type: Shipment Sent By: Date/Time: Carrier: Shipment Receipt By: Date/Time: Carrier: Custody Transferred to: Date/Time: Carrier: Custody Transferred to: Date/Time: Carrier: Custody Transferred to: Date/Time: Carrier:

WVSMP Deployed Retrieved Dosimeter Dosimeter ID Location ID (Sample ID) ID Date Time Date Time Comments NYTLDBK Background on the fence along the north driveway from Ashford Hollow Road to the Ashford Office Complex NYTLDTC Deployment time is for lead cave Transit control – transit doses from storage. vendor ship-out of dosimeters through return to vendor; includes low dose area storage NYTLDLC Lead Cave dosimeter deployed in the low background storage location (e.g. WVDP dosimetry laboratory lead cave). DNTLD33 Outside SDA fence near corner of WVDP perimeter fence and SDA fence. South of SDA Gate #15 DNTLD43 Western perimeter fence of SDA adjacent to the main SDA access Gate #15 SDATLD01 South Fence at approximate center line of Trench 11 SDATLD02 East fence middle of southern trenches next to Survey Point 9

1 This form may be modified to accommodate changes to locations or nomenclature as needed.

A1 Table A-1. SDA Environmental Dosimeter Deployment/Retrieval Form continued1

Source: NYSERDA

WVSMP Deployed Retrieved Dosimeter Dosimeter ID Location ID (Sample ID) ID Date Time Date Time Comments DNTLD19 Eastern perimeter fence north of SDA buffer area access gate SDATLD03 East fence middle of northern trenches next to Survey Point 6 SDATLD04 North fence approximate center between trenches 3 and 4 DNTLD53 Northwestern corner perimeter fence of SDA SDATLD05 West fence middle of northern trenches next to and south of Survey Point 1 SDATLD06 West fence middle of southern trenches south of Survey Point 15

Additional Comments:

Post-Retrieval Custody by: Date/Time: Carrier: Custody Transferred to: Date/Time: Carrier: Custody Transferred to: Date/Time: Carrier: Return Shipment Sent by: Date/Time: Carrier: Vendor Destination: Bill of Lading Received

or Tracking #: Date/Time: ______

1. This form may be modified to accommodate changes to locations or nomenclature as needed.

Appendix B – SDA Environmental Dosimeter Location Figures

Figure B-1. NYTLDBK Background Environmental Dosimeter Location

Source: NYSERDA

Figure B-2. WVDP Dosimetry Laboratory Location

Source: NYSERDA

Figure B-3. SDA Environmental Dosimeter Locations Map

Source: NYSERDA

This page intentionally left blank.

Leachate Monitoring Plan for the State-Licensed Disposal Area

ENV501.06

New York State Energy Research and Development Authority West Valley Site Management Program

West Valley, NY

06/19/2019

This page intentionally left blank.

1 Purpose

The purpose of the Leachate Monitoring Plan is to:

1. Define a process for obtaining and assessing leachate level measurement data. 2. Identify short-term changes and long-term trends in the State-Licensed Disposal Area (SDA) trench leachate levels. 3. Define responses to short-term changes in leachate levels in the SDA trench sumps. 4. Identify regulatory notification requirements pertaining to leachate level measurements. 2 Scope

2.1 Measurement Frequency

Routine leachate elevation measurements will be conducted monthly or quarterly at the trench sump locations listed below in Table 2-1, in conjunction with quarterly SDA groundwater elevation measurements.

Table 2.1. Trench Sump Monitoring Frequency

Source: NYSERDA

Trench Measurement Sump ID Frequency 1 Q 2 Q 3 Q 4 Q 5 Q 8 Q 9 Q 10N Q 10S Q 11 Q 12 Q 13 M/Q 14 M/Q WP-91 M/Q Key: Q Quarterly measurement frequency M Monthly measurement frequency

ENV501.06 Leachate Monitoring Plan for the SDA 1

A nonroutine leachate elevation measurement will be conducted in each of the trenches in the event that:

1. An earthquake is felt in the vicinity of the site; 2. Slope movement, such as slumping, is noted on the SDA Inspection Checklist; 3. Trench cap subsidence is noted on the SDA Walkover Inspection Checklist; or 4. Construction activity disturbs the surface of a particular trench.

Any modifications made to a trench sump that could impact leachate elevation measurements require the trench with the sump modifications to be remeasured.

These measurements will be conducted, as environmental conditions allow, within two business days of the notation of the event.

2.2 Monitoring Methods

Leachate levels will be monitored using one of the following methods. Each method is capable of detecting, at a minimum, a three-inch change in a trench sump leachate level. The method used to measure the leachate level in each trench, along with the measurement result, will be reported in the routine SDA quarterly reports.

1. The conductivity method involves the use of an electronic liquid level indicator suspended from a cable with 0.01-foot markings. The indicator provides an audio signal when it contacts the top of the liquid surface in the well. The depth at which the audio signal is heard is recorded and converted to a leachate level elevation. 2. The “sounding” method involves the use of a weight suspended from a cable with one-inch markings. In the sounding method, the suspended weight is lowered into the well until it “plops” into the liquid surface. The depth at which the “plopping” is heard is recorded and converted to a leachate level elevation. 3. The steel-tape method uses a steel measuring tape, coated with chalk, which is lowered into the disposal trench sump. The distance to the liquid is read by observing the point on the tape at which the chalk is dampened or rinsed off. This distance is subtracted from the known elevation of the top of the sump to obtain the elevation of the liquid surface.

2.3 Monitoring Procedure

Leachate level monitoring will be performed in accordance with a procedure that specifies the steps in the monitoring process.

ENV501.06 Leachate Monitoring Plan for the SDA 2

3 Data Assessment, Follow-up Actions and Notifications

3.1 SDA Leachate Monitoring Flowchart

Leachate level data will be assessed and acted upon in accordance with the leachate monitoring flowchart that is attached to this plan (Attachment A). This flowchart also defines the leachate level conditions that will trigger New York State Department of Environmental Conservation (DEC) notification for routine quarterly leachate level measurements.

3.2 Nonroutine Measurements

For nonroutine measurements conducted after one of the events listed in Section 2.1, the DEC Radioactive Materials Management staff will be notified within two business days of confirming any six inch or greater change in leachate elevation.

3.3 Trench Leachate Assessment Form

Leachate level data will be assessed and compared with the previous leachate level data using the attached form (Attachment B). The SDA Leachate Monitoring Flowchart (Attachment A) defines the triggers that will require notification of DEC. In the notes section of the Trench Leachate Assessment Form (Attachment B), the reference elevation datum should be noted. The reference elevation datum are recorded in the North American Datum 83 and the National Geodetic Vertical Datum 88 Coordinate System.

3.4 Contingency for Rising Leachate Levels

If leachate levels exhibit an increasing trend in elevation over time, the New York State Energy Research and Development Authority (NYSERDA) will first initiate an investigation on the effectiveness of the Infiltration Controls (IC) at the SDA, including both the geomembrane cover and slurry wall. NYSERDA relies on the ICs to keep precipitation and groundwater from infiltrating the SDA trenches. If it is clear that the ICs are not functioning as designed, NYSERDA will initiate repairs or upgrades of the ICs to address the problem. The goal is to stabilize leachate levels in the trench(es). If the ICs are functioning as designed, but leachate levels continue to rise, NYSERDA will consult with DEC regarding contingency actions to take, if any. These contingency actions could include performing additional investigations to evaluate the cause of the leachate increase, installing surface water flow and drainage system changes to improve the movement of water away from the trenches, or enhancing the existing infiltration controls.

ENV501.06 Leachate Monitoring Plan for the SDA 3

4 Reporting

Completed measurement worksheets, leachate level trend reports, maintenance, and miscellaneous activities are filed in the West Valley Site Management Program central files.

5 Appendices

Appendix A: SDA Leachate Monitoring Flowchart (one page).

Appendix B: Trench Leachate Assessment Form (one page).

ENV501.06 Leachate Monitoring Plan for the SDA 4

Appendix A – SDA Leachate Monitoring Flowchart

Source: NYSERDA

Measure leachate levels at the same time as the monthly or quarterly SDA groundwater elevation measurements, weather conditions permitting.

Is the leachate level Remeasure leachate level in measurement >+/-6" affected trench sump and perform from previous quarter Yes field inspection of the affected OR a >+/- 10" trench sump within five business cumulative change over days, weather conditions the past two quarters? permitting.

Does the leachate level Enter leachate level data point remeasurement confirm Perform a walkaround in the leachate level database. a change of >+/-6" Yes inspection of the affected from the previous trench and slopes within five quarter or a >+/-10" business days, weather cumulative change over conditions permitting. the past two quarters? Transmit leachate level data to DEC in routine monthly or quarterly emails and in quarterly reports. Notify DEC of leachate level changes and field inspection No results by phone.

Annually, review long-term leachate level trends and Record explanation on field report trends in annual report data sheet. Initiate sump or to DEC. equipment repairs, as needed. Consult with DEC regarding follow-up actions. Record Action Plan (Memo-to-File) with a copy to DEC. Consult with DEC as appropriate.

This page intentionally left blank.

Appendix B - Trench Leachate Assessment Form

Source: NYSERDA Leachate Level Leachate Level Change from Trench Current Leachate Level Elevation Previous Change from Elevations Two Two Quarters Reportable Elevation (ft) Quarter (ft) Previous Quarter (ft) Quarters Ago (ft) Ago (ft) (Y/N)? 1

10S

10N

14 NOTES: ______Reportable: Data is reportable within two business days to the DEC if the level shows a change of >+/- 6 inches (0.5 feet) from the previous quarter or a >+/- 10 inches (0.83 feet) cumulative change over the past two quarters. Assessment Performed by: Date:

Assessment Reviewed by: Date: B1

This page intentionally left blank.

Groundwater Monitoring Plan for the State-Licensed Disposal Area (SDA) at West Valley

ENV502.06

New York State Energy Research and Development Authority West Valley Site Management Program

West Valley, NY

06/19/2019

This page intentionally left blank.

Acronyms and Abbreviations

AMSL Above Mean Sea Level BGS Below Ground Surface DEC New York State Department of Environmental Conservation EPA U.S. Environmental Protection Agency NAVD North American Vertical Datum NTU Nephelometric Turbidity Unit NYSERDA New York State Energy Research and Development Authority PARCC Precision, Accuracy, Representativeness, Comparability, and Completeness Plan SDA Groundwater Plan PQL Practical Quantitation Limit QA Quality Assurance SCL Secondary Concentration Limit SDA State-Licensed Radioactive Waste Disposal Area µCi/mL Microcuries per Milliliter µg/L Micrograms per Liter µmho/cm Microhom per Centimeter UPL Upper Prediction Limits UTL Upper Tolerance Limits VOC Volatile Organic Compound

1 Purpose

The purpose of the State-Licensed Radioactive Waste Disposal Area (SDA) Groundwater Monitoring Plan (Plan) is to define a groundwater monitoring program that provides:

• Groundwater data of sufficient quality and quantity to allow detection of the migration of radionuclides and volatile organic compounds from the SDA through groundwater. • Information on hydrologic conditions in the vicinity of the disposal trenches. This Plan applies to all groundwater monitoring activities at the SDA and will be reviewed annually to determine whether events of the previous year necessitate revisions to the Plan.

2 Water Elevation Measurements

2.1 Groundwater Elevation Measurement Network

Groundwater elevation measurements will be conducted at the 21, 1100-series monitoring wells, and the piezometer and slit-trench monitoring well locations at the frequencies identified in Tables 2-1, 2-2, and 2- 3 (see Figure 2-1). Construction details of the 1100-series wells, piezometers, and slit-trench wells are provided in Tables 2-1, 2-2, and 2-3, respectively.

2.2 Groundwater Elevation Measurement Frequency

Groundwater elevations are measured monthly or quarterly in three separate flow zones: the weathered Lavery till, the unweathered Lavery till, and the Kent recessional unit. The groundwater elevation in each 1100-series well, piezometer, and slit-trench well is measured within a 24-hour period wherever practicable. The New York State Energy Research and Development Authority (NYSERDA) will attempt to coordinate water elevation measurements for SDA wells with measurements conducted by the United States Department of Energy for the West Valley Demonstration Project wells on the south plateau such that the water elevations in both sets of wells are measured within seven days of each other.

ENV502.06 Groundwater Monitoring Plan for the SDA at West Valley 1

Figure 2-1. SDA Groundwater Monitoring Well Locations

Source: NYSERDA

ENV502.06 Groundwater Monitoring Plan for the SDA at West Valley 2

Table 2.1. Monitoring Well Construction Summary, 1100 Series

Source: NYSERDA

Well Screened Screened Geologic Date Measurement Well ID Depth Interval Interval (ft Unit Installed Frequency (ft BGS) (ft BGS) AMSL NAVD 88) Screened 1101A 3/13/90 16 6 - 16 1373.20 – 1363.20 W/U M/Q 1101B 3/13/90 30 20 - 30 1359.25 – 1349.25 U M/Q 1101C 3/12/90 109 94 - 109 1284.96 – 1269.96 L M/Q 1102A 3/06/90 17 7 - 17 1375.54 – 1365.54 W/U Q 1102B 3/05/90 31 21 - 31 1361.42 – 1351.42 U Q 1103A 3/20/90 16 6 - 16 1373.73 – 1363.73 W/U Q 1103B 3/20/90 36 21 - 36 1358.66 – 1343.66 U Q 1103C 3/19/90 121 106 - 121 1273.34 – 1258.34 L/O Q 1104A 4/12/90 19 4 - 19 1371.95 – 1356.95 W/U Q 1104B 4/12/90 36 21 - 36 1354.93 – 1339.93 U Q 1104C 4/11/90 124 114 - 124 1261.79 – 1251.79 L/O Q 1105A 4/18/90 21 11 - 21 1354.64 – 1344.64 U Q 1105B 4/17/90 36 21 - 36 1344.85 – 1329.85 U Q 1106A 4/19/90 16 6 - 16 1368.19 – 1358.19 W/U M/Q 1106B 4/19/90 31 21 - 31 1353.15 – 1343.15 U M/Q 1107A 4/16/90 19 4 - 19 1373.00 – 1358.00 W/U Q 1108A 3/07/90 16 6 - 16 1374.76 – 1364.76 W/U M/Q 1109A 5/01/90 16 6 - 16 1368.69 – 1358.69 W/U M/Q 1109B 5/01/90 31 16 - 31 1357.85 – 1342.85 U M/Q 1110A 3/16/90 20 10 - 20 1366.88 – 1356.88 W/U Q 1111A 3/07/90 21 11 - 21 1369.05 – 1359.05 U Q

Key for Qualifier codes: W/U Weathered Lavery Till/Unweathered Lavery Till U Unweathered Lavery Till L Lacustrine Unit (Kent Recessional Sequence) L/O Lacustrine/Outwash – Kame Sand and Gravel (Kent Recessional Sequence) M Monthly Measurement Frequency Q Quarterly Measurement Frequency

ENV502.06 Groundwater Monitoring Plan for the SDA at West Valley 3

Table 2-2. Piezometer Installation Details

Source: NYSERDA

Well Screened Geologic Piezometer Date Screened Interval Measurement Depth Interval Unit ID Installed (ft AMSL NAVD 88) Frequency (ft BGS) (ft BGS) Screened 1S-91 04/15/91 14 6.5 - 14 1376.38 – 1368.88 W/U Q

2S-91 04/16/91 16 6 - 16 1378.87 – 1368.87 W/U Q

3S-91 04/03/91 13.5 6 - 13.5 1372.60 – 1365.10 W/U M/Q

4S-91 04/05/91 11 6 - 11 1374.48 – 1369.48 W/U M/Q

4D-91 04/05/91 29 14 - 29 1366.48 – 1351.48 U M/Q

6S-91 04/09/91 11 6 - 11 1375.52 – 1370.52 W/U M/Q

6D-91 04/08/91 25 15 - 25 1366.52 – 1356.52 U M/Q

9S-91 04/01/91 9 4 - 9 1377.03 – 1372.03 W/U M/Q

9D-91 03/29/91 26 15 - 25 1366.03 – 1356.03 U M/Q

10S-91 03/28/91 14 4.9 - 12.4 1374.57 – 1367.07 W/U M/Q

15S-91 04/04/91 14 5.5 - 13 1373.41 – 1365.91 W/U M/Q

16D-91 04/17/91 26 15 - 25 1364.31 – 1354.31 U M/Q

17S-91 04/17/91 12 6 - 11 1377.55 – 1372.55 W/U M/Q

18S-91 04/18/91 14 6.5 - 14 1374.02 – 1366.52 U M/Q

21S-91 04/10/91 20 11 - 16 1370.52 – 1365.52 U M/Q

22S-91 12/31/91 21 16 - 21 1366.74 – 1361.74 U M/Q

24S-91 01/02/92 18 8 - 18 1372.32 – 1362.32 W/U M/Q

B-14 04/08/92 32 14 - 24 1365.89 – 1355.89 U M/Q

P1-95 09/27/95 7.7 2.7 - 7.7 1365.21 – 1360.21 W M

Key: M = Monthly Measurement Frequency M/Q = Monthly and Quarterly Measurement Frequency Q = Quarterly Measurement Frequency U = Unweathered Lavery Till W = Weathered Lavery Till W/U = Weathered Lavery Till/Unweathered Lavery Till

ENV502.06 Groundwater Monitoring Plan for the SDA at West Valley 4

Table 2-3. Slit-Trench Well Installation Details

Source: NYSERDA

Screened Screened Interval Slit-Trench Date Well Depth Geologic Unit Measurement Interval (ft AMSL NAVD Well ID Installed (ft BGS) Screened Frequency (ft BGS) 88)

SMW-1 11/20/92 7.00 6.83 - 4.58 1376.55 – 1374.30 W M/Q

SMW-2 10/27/92 6.00 5.83 - 3.58 1377.42 – 1375.17 W M/Q

SMW-3 10/27/92 6.00 5.83 - 3.58 1377.35 – 1375.10 W M/Q

SMW-4 11/19/92 11.00 10.83 - 8.58 1370.35 – 1368.10 W/U M/Q

SMW-5 11/20/92 7.00 7.08 - 4.83 1373.39 – 1371.14 W M/Q

SMW-6 11/19/92 7.00 6.83 - 4.58 1376.17 – 1373.92 W M/Q

SMW-7 11/19/92 6.50 6.33 - 4.08 1376.27 – 1374.02 W M/Q

SMW-8 06/07/93 7.00 6.00 - 3.75 1373.69 – 1371.44 W M/Q

SMW-9 11/19/92 6.00 5.83 - 3.58 1373.49 – 1371.24 W M/Q

Key: M/Q = Monthly and Quarterly Measurement Frequency W = Weathered Lavery Till W/U = Weathered Lavery Till/Unweathered Lavery Till

ENV502.06 Groundwater Monitoring Plan for the SDA at West Valley 5

2.3 Groundwater Elevation Measurement Procedures

Groundwater level measurements are performed in accordance with the methods described in applicable procedures. The procedures describe the methodology, protocols, and quality assurance (QA) requirements for conducting the groundwater level measurements in a manner that provides consistent high-quality data.

2.3.1 Groundwater Elevation Measurements

Water levels are measured by lowering an electronic water level indicator probe into the well. Water level indicator cables have graduations of 0.01 feet. Audio and visual indicators at the surface signal the depth where the probe encounters the top of the water surface. The probe will be lowered to the top of the water surface a minimum of three times to ensure the correct measurement is collected. Depth-to-water is referenced from the top of the well casing on the north side of the well, which is then converted to an elevation above mean sea level (AMSL).

2.3.2 Equipment Decontamination

To minimize the cross-contamination of SDA wells, piezometers, and slit-trench wells, nondisposable, nondedicated equipment used in the water level measurement process is decontaminated after use at each location. To avoid the generation of potentially hazardous decontamination fluids, decontamination of equipment is conducted using clean disposable wipes and rinsing/spraying with deionized water.

2.3.3 Equipment Maintenance

Field instruments and equipment used for groundwater elevation measurements are operated, serviced, and maintained as needed, in accordance with manufacturer's guidelines and recommendations, as well as by criteria set forth in applicable SDA groundwater monitoring program procedures. Documentation of routine and special maintenance information is contained in an instrument specific-logbook or a reference file.

2.3.4 Data Assessment

Groundwater elevation measurement data are reviewed, validated, and reported in accordance with SDA groundwater monitoring program procedures.

ENV502.06 Groundwater Monitoring Plan for the SDA at West Valley 6

3 Groundwater Sampling and Analysis

3.1 1100-Series Well Network

The 1100-series groundwater monitoring well network consists of 21 wells located within or just outside the SDA fence. The wells, which monitor the primary geologic units at the SDA including the weathered Lavery till, the unweathered Lavery till, and the Kent recessional sequence, are shown in Figure 2-1. Well construction details are provided in Table 2-1.

3.2 Parameters and Monitoring Frequency

Sampling of the 21, 1100-series groundwater monitoring wells for the groundwater program parameters is conducted on a semiannual or an annual basis, as shown in Table 3-1. Minimum detection limit goals for the SDA groundwater monitoring program are provided in Tables 3-1 and 3-2 as detection limit and practical quantitation limit (PQL), respectively.

3.3 Well Sampling and Analysis Procedures

Each of the sampling and analysis activities and QA requirements for the 1100-series wells are detailed in written procedures. The procedures establish quality requirements for sampling, analysis, and data assessment for the SDA groundwater monitoring program in accordance with New York State Department of Environmental Conservation (DEC) guidance.

3.3.1 Well Purging

Prior to sample collection, purging of groundwater in the wells is conducted. Wells that historically have not shown adequate rates of recharge to allow sample collection after purging are not purged. Static water elevations are measured at each well and total well depth data are used to calculate the standing volume of water in each well. Wells capable of yielding adequate water to allow sample collection after purging are purged using either dedicated bladder pumps or bailers.

For well purging using bladder pumps, purging is conducted with the bladder pump set at a pumping rate of approximately 1.5 gallons per minute, and three standing well volumes are removed from the well. Wells not capable of yielding three standing well volumes at a pumping rate of approximately 1.5 gallons per minute are purged until the field water quality parameters are stable, or to dryness, whichever comes first, and allowed to recharge prior to sampling. Wells purged with bailers are bailed until three standing well

ENV502.06 Groundwater Monitoring Plan for the SDA at West Valley 7

Table 3-1. SDA Groundwater Sampling and Analysis, 1100-Series Wells

Source: NYSERDA

Parameter Analytical Method1 Detection Limit2 Frequency Radiological3

Gross Alpha SW9310/EPA 900.0 3.0 pCi/L Semiannual

Gross Beta SW9310/EPA 900.0 4.0 pCi/L Semiannual

Tritium EPA 906.0 100.0 pCi/L Semiannual

EPA 901.1 20.0 pCi/L Annual Gamma Emitters by Spectroscopy4

C-14 As per lab 50.0 pCi/L Annual

I-129 As per lab 1.0 pCi/L Annual

Sr-90 As per lab 1.0 pCi/L Annual

Tc-99 As per lab 5.0 pCi/L Annual

Chemical

RCRA Appendix IX SW8260C See Table 3-2 Annual VOCs5 Field Water Quality Measurements pH As specified in 0.01 Std. Units Semiannual procedure

Specific As specified in 1 μmho/cm at 25oC Semiannual Conductance procedure

Temperature As specified in 0.1oC Semiannual procedure

Turbidity As specified in 0.02 NTU Semiannual procedure

1 Proposed method in accordance with “EPA Test Methods for Evaluating Solid Waste, Physical/Chemical Methods” (SW- 846) (2007 or most recent revision); “EPA Prescribed Procedures for Measurement of Radioactivity in Drinking Water” (1980 or most recent revision); or other most current EPA-approved or laboratory-specific methods. 2 1 pCi/L is equal to 1.0E-06 µCi/L or 1E-03µCi/mL, or simply stated, one pCi/L is equal to one part per trillion in a liter of groundwater, and 1 µCi/L, is equal to one part per million in a liter of groundwater. 3 Filtered in the field. 4 Individual contract-required gamma emitter detection limits are based on the detection limit for cesium-137. 5 Samples are analyzed for a prescribed subset of RCRA Appendix IX VOCs.

ENV502.06 Groundwater Monitoring Plan for the SDA at West Valley 8

Table 3-2. RCRA Appendix IX Volatiles, Groundwater Detection Limit Goals

(Based on Method [SW8260C6])

Source: NYSERDA

Analyte / PQL Analyte/ PQL

Component (µg/L) Component (µg/L) Acetone 10 Ethyl Methacrylate 5 Acetonitrile 100 2-Hexanone 10 Acrolein 50 Isobutanol 50 Acrylonitrile 5 Methacrylonitrile 5 Allyl Chloride 10 Methylene Bromide 5 Benzene 5 Methylene Chloride 5 Bromodichloromethane 5 Methyl Iodide 5 Bromoform 5 Methyl Methacrylate 5 Bromomethane 10 4-Methyl-2-Pentanone 10 2-Butanone 10 Pentachloroethane 5 Carbon Disulfide 5 Propionitrile 10 Carbon Tetrachloride 5 Styrene 5 Chlorobenzene 5 1,1,1,2-Tetrachloroethane 5 Chloroethane 10 1,1,2,2-Tetrachloroethane 5 Chloroform 5 Tetrachlorethylene 5 Chloromethane 10 Toluene 5 Chloroprene 5 1,1,1-Trichloroethane 5 Dibromochloromethane 5 1,1,2-Trichloroethane 5 1,2-Dibromo-3- 5 Trichloroethene 5 Chloropropane 1,2-Dibromoethane 5 Trichlorofluoromethane 5 trans-1,4-Dichloro-2- 5 1,2,3-Trichloropropane 5 Butene3 Dichlorodifluoromethane 5 Vinyl Acetate 5 1,1-Dichloroethane 5 Vinyl Chloride 10 1,2-Dichloroethane 5 Xylene (M&P) 5 1,1-Dichloroethylene 5 Xylene (O) 5 trans-1,2-Dichloroethylene 5 Xylene (total) 5 1,2-Dichloroethylene 5 (total) 1,2-Dichloropropane 5 cis-1,3-Dichloropropene 5 trans-1,3-Dichloropropene 5 1,4-Dioxane 150 Ethylbenzene 5

6 Or most current EPA-approved update (see Table 3-1).

ENV502.06 Groundwater Monitoring Plan for the SDA at West Valley 9

volumes are evacuated or to dryness, whichever comes first.

3.3.2 Field Water Quality Measurements

Field measurements of temperature, pH, conductivity, and turbidity are conducted at each well as allowed by the volume of water yielded from each well during each sampling event. Generally, field measurements are collected at routine intervals during purging to assess the stability of those parameters as purging is conducted. Field parameters are also collected after sampling is complete. To allow all available water to go toward fulfilling the volume requirement for laboratory analysis, field measurements may be measured only after sample collection at low-yield wells that are not purged.

3.3.3 Sample Collection

If sufficient recharge occurs, sampling should be conducted within three hours of purging. If sufficient recharge does not occur within three hours of purging, wells are sampled for as many parameters as possible using the volume of water available in the well within 24 hours of purging.

Samples are collected according to the following priority: (1) tritium; (2) VOCs; (3) gross alpha, gross beta; (4) gamma emitters by gamma spectroscopy; and (5) carbon-14, iodine-129, strontium-90, and technicium- 99.

During sampling events where a parameter in the list above is not sampled (e.g., VOCs are sampled annually, while gross alpha and gross beta are sampled semiannually), the remaining parameters in the list will shift up one position in priority. The relative order of the remaining parameters will not change. Where sample volumes are insufficient to analyze for all required parameters, those analyses not performed will move up in the priorities list to follow gross beta during the next sampling event.

3.3.4 Sample Containers, Preservation, and Holding Time

To ensure the integrity of SDA groundwater samples, all samples are collected in appropriate containers and preserved as needed. Requirements for sample containers, preservation, and holding times for SDA groundwater sampling/analysis are documented in applicable procedures.

3.3.5 Quality Control Samples

Field and analytical quality control samples are used to check analytical results, sampling techniques, sample integrity, and preservation. Quality control samples to be used in the SDA groundwater monitoring

ENV502.06 Groundwater Monitoring Plan for the SDA at West Valley 10 program include field and analytical duplicates, matrix spike/matrix spike duplicates, and analytical and temperature trip blanks.

The use of quality control samples for SDA groundwater sampling/analysis is specified in applicable procedures.

3.3.6 Sample Custody

Sample custody procedures are used to ensure that the integrity of the samples is maintained during collection, transportation, storage, analysis, and reporting. Sample custody documentation for SDA groundwater sampling/analysis includes the use of:

• Sample identification numbers. • Sample tags or labels. • Custody seals. • Chain-of-custody records. • Field logbooks. • Sample collection forms. • Analytical request forms. • Analytical records. Sample custody procedures were prepared to comply with DEC protocols using EPA-approved analytical procedures or equivalent.

3.3.7 Equipment Decontamination

To minimize the cross-contamination of SDA groundwater monitoring wells, dedicated bladder pumps, and bailers are used for sampling purposes. Nondisposable, nondedicated equipment used in the sampling process is decontaminated after use at each well. To avoid the generation of potentially hazardous decontamination fluids, decontamination of equipment is conducted using clean disposable wipes and rinsing/spraying with deionized water.

3.3.8 Equipment Calibration and Maintenance

Laboratory, field instruments, and equipment used for SDA groundwater sampling/analysis are operated, calibrated, serviced, and maintained as needed, in accordance with manufacturer's guidelines and recommendations as well as by criteria set forth in applicable analytical references and SDA groundwater monitoring program procedures. Field equipment is inspected at least twice daily while in use: once before start-up and again before returning the equipment to storage at the end of the day.

ENV502.06 Groundwater Monitoring Plan for the SDA at West Valley 11 Documentation of all routine and special maintenance and calibration information is contained in an instrument specific-logbook or a reference file.

3.3.9 Sample Analysis

Samples are analyzed at a New York State Department of Health Environmental Laboratory Approval Program-approved laboratory in accordance with DEC’s protocols using EPA-approved analytical procedures or equivalent.

3.3.10 Data Reduction and Validation

The groundwater data are reduced, reviewed, validated, and reported in accordance with the laboratories’ QA manuals, analytical method references and procedures, and SDA groundwater monitoring program procedures. The laboratories perform internal data review and verification before the data are initially reported, after which the data are validated by QA chemists and data validators who are independent of the laboratory. When the environmental contractor receives the prevalidated data from the laboratory, they will conduct an initial prevalidation review of the data, and will notify NYSERDA within two weeks of receipt of the data of any potential issues such that resampling, if required, can be prepared for and carried out expeditiously. After this initial prevalidation review, the SDA groundwater data are assessed through the evaluation of the data quality indicators known as precision, accuracy, representativeness, completeness, and comparability (i.e., the Precision, Accuracy, Representativeness, Comparability, and Completeness [PARCC] parameters). PARCC targets are established for particular analytes and applied throughout the data collection process. Quantitative and qualitative statements regarding PARCC targets are specified in applicable procedures. Validated data are reported to NYSERDA.

3.3.11 Groundwater Data Assessment

3.3.11.1 Tritium, Gross Alpha, and Gross Beta

Upper tolerance limits (UTLs) and upper prediction limits (UPL) for each parameter at each well were calculated to determine the acceptable data range for each parameter and location. For data that are predominantly nondetects or data that are not normally distributed, a nonparametric UPL will be used instead of a UTL or UPL.

As new validated sample data is available, the results for tritium, gross alpha, and gross beta for each well are compared to their respective UTLs, UPLs, or nonparametric UPLs to determine if the data passes the initial test (i.e., is the data less than the UTL, UPL, or nonparametric UPL). This comparison is completed

ENV502.06 Groundwater Monitoring Plan for the SDA at West Valley 12 with the collection of each new data set (semiannually) and is used to determine if the new result is notably different than the historical results. If a sample result does not exceed its UTL, UPL, or nonparametric UPL, then routine monitoring of the well for that parameter continues.

Due to the low detection limits for tritium (100 picocuries per liter) used in this program, a secondary concentration limit (SCL) will be used to evaluate the tritium results. The SCL (600 pCi/L) was derived from the “industry standard” range of tritium detection limits. If a tritium result exceeds its UTL, UPL, or nonparametric UPL, then the result is compared to the tritium SCL. If the tritium result also exceeds the tritium SCL, NYSERDA’s Environmental Support Contractor will notify NYSERDA immediately (i.e., the contractor will not wait until formal submittal of the associated report to notify NYSERDA of any exceedances). Similarly, if a gross alpha or gross beta result exceeds its UTL, UPL, or nonparametric UPL, NYSERDA’s Environmental Support Contractor will notify NYSERDA immediately (i.e., the contractor will not wait until formal submittal of the associated report to notify NYSERDA of any exceedances). NYSERDA will evaluate the data and notify the DEC within two business days to discuss whether resampling is required for the exceeding parameter.

During the consultation with DEC, NYSERDA will provide information on the results of the statistical assessment, results of any comparisons with SCLs, and the historical data for the parameter and well in question. If the decision is made not to resample, routine monitoring of the well for the exceeding parameter continues. If the decision is made to resample, a new sample is collected from the well and analyzed for the constituent in question. The new result is then compared again to the corresponding UPL. If the new result does not exceed its UPL, routine monitoring of the well for that parameter continues. If the new result exceeds the UPL, the constituent is considered to have been detected at a level significantly higher than the well's historical concentration. DEC is formally notified at this point (per Section 5.1). This data assessment process is depicted graphically in Figure 3-1.

The calculated UTL and UPL’s will be reviewed and evaluated every five years after implementation to determine whether and when they should be updated. The procedure for the review, evaluation and calculation of the UTLs and UPLs is presented in ENV009, Assessment and Reporting of SDA Data.7

7 NYSERDA, pg. 13.

ENV502.06 Groundwater Monitoring Plan for the SDA at West Valley 13

Figure 3.1. Statistical Testing for Gross Alpha, Gross Beta, and Tritium Data

Source: NYSERDA

ENV502.06 Groundwater Monitoring Plan for the SDA at West Valley 14

3.3.11.2 Other Radiological Constituents

Analytical control chart methodology will be used to evaluate the sample results for other radiological constituents (gamma emitters, iodine-129, carbon-14, strontium-90, and technicium-99). Validated results for these constituents at each well are compared to statistics calculated from historical results (i.e., the mean and standard deviation of historical results for a given analyte from an individual well form the basis for evaluating the new result at that well). An analytical result will be considered a positive detection when it meets all of the following criteria:

(1) It is greater than zero. (2) It is greater than the achieved detection limit for the analysis. (3) It is greater than the analytical uncertainty of the analysis. (4) It is not qualified. A minimum of five positive detections of the analyte in the past 10 years for the well of interest will be required to calculate the mean and standard deviation. NYSERDA will notify DEC of any validated, positive result meeting any of the following four criteria:

(1) The result exceeds the mean plus three standard deviations. (2) The result is the third consecutive result exceeding the mean plus two standard deviations. (3) The result is the seventh consecutive positive result falling above the mean. (4) The result is the fifth in a series exhibiting a successive increase. If a qualifier is assigned to an analytical result which would otherwise have exceeded the first notification criterion (i.e., exceeded the mean plus three standard deviations), or would have continued along a path toward exceeding any of the other notification criteria, NYSERDA will initiate discussions on follow-up actions with its groundwater monitoring contractor and DEC (per Section 5.1).

ENV502.06 Groundwater Monitoring Plan for the SDA at West Valley 15

3.3.11.3 Volatile Organic Compounds

Validated VOC results are compared to DEC’s protocols using EPA-approved analytical procedures or equivalent.

Data are assessed for trends if:

(1) A validated VOC concentration in a well exceeds the groundwater quality standard or guidance value. (2) An “estimated” VOC concentration exceeds the groundwater quality standard or guidance value. (3) A validated VOC concentration exceeds the PQL, for a compound not listed in groundwater quality standards or guidance. NYSERDA will notify DEC of VOC exceedances and trends (per Section 5.1).

ENV502.06 Groundwater Monitoring Plan for the SDA at West Valley 16

4 Well Inspections and Maintenance

4.1 External Well Inspections and Maintenance

External inspections and maintenance of all wells listed in Tables 2-1, 2-2, and 2-3 are performed at least semiannually. These activities may include:

• Maintenance of well locks. • Replacement of missing well tags. • Inspection of concrete pads and protective casings. • Inspection of external tubing and fittings, if present. Well maintenance activities will be initiated in accordance with well inspection results, if warranted. Any inspection results noted requiring maintenance will be carried out prior to the following semiannual inspection and maintenance event, and these activities noted in the quarterly reports submitted to NYSERDA. NYSERDA will provide a copy of the external well inspection along with a description of any well maintenance activities completed to DEC on a quarterly basis.

4.2 Internal Well Inspections and Maintenance

Internal inspections of the 1100-series wells (Table 2-1) are performed every two years, in conjunction with the annual sampling event conducted that year. These activities include:

• Measurement of total well depth for assessing sediment accumulation. • Inspection of bladder pumps. • Inspection of bailers. The internal well inspection activities will be noted in the annual report generated in association with the internal well inspection activity. Well maintenance activities are initiated in accordance with well inspection results, if warranted. Any inspection results noted requiring maintenance will be carried out prior to the following semiannual/annual sampling event, and these activities noted in the semiannual/annual report submitted to NYSERDA in association with the maintenance activities. NYSERDA will provide a copy of the internal well inspection, along with a description of any well maintenance activities completed to DEC on a quarterly basis.

ENV502.06 Groundwater Monitoring Plan for the SDA at West Valley 17

5 Notifications and Reporting

5.1 Notifications

NYSERDA will notify DEC within two business days, by telephone and/or email, of determining that:

(1) A tritium, gross alpha, or gross beta result from an 1100-series monitoring well is significantly higher than prior results as shown by the sample result failing the UTL test (or initial nonparametric UPL test, as applicable); and, for tritium exceeding the SCL, and the resampling of the well for that constituent failing the second-phase UTL/UPL test. (2) A gamma emitter, iodine-129, carbon-14, strontium-90, or technicium-99 result meets any of the four notification criteria specified in Section 3.3.11.2. (3) An initial validated VOC concentration in an 1100-series monitoring well sample exceeds the groundwater quality standard or guidance value. (4) An initial “estimated” VOC concentration in an 1100-series monitoring well sample exceeds the groundwater quality standard or guidance value. (5) An initial validated VOC concentration in an 1100-series monitoring well sample exceeds the PQL, for a compound not listed in groundwater quality standards or guidance. (6) There is an increasing VOC trend in a well where: (a) The validated concentration exceeds the groundwater quality standard or guidance value. (b) The “estimated” concentration exceeds the groundwater quality standard or guidance value. (c) The validated concentration exceeds the PQL, for a compound not listed in groundwater quality standards and guidance. NYSERDA will consult with DEC regarding required follow-up actions.

5.2 Reporting

5.2.1 Routine Reports

NYSERDA submits SDA groundwater monitoring information to DEC in routine SDA reports for the period in which water elevations or validated analytical data and results of statistical testing are received by NYSERDA. All reports, data, and miscellaneous activities are filed in the West Valley Site Management Program central files.

5.2.2 Information Included

The groundwater monitoring information includes:

• A summary of the measurements or sampling conducted during the reporting period. The summary will include such information as the identity of the wells sampled, parameters sampled for and analyzed, problems encountered in sampling or analysis, and a discussion of any significant analytical results.

ENV502.06 Groundwater Monitoring Plan for the SDA at West Valley 18 • Water level information. • Field conditions. • Results of field-measured and laboratory-analyzed parameters. • Results of statistical testing. • QA issues. • Well inspection and maintenance activities. • Quarterly water table maps for the weathered Lavery till and the Kent recessional unit. • Quarterly tabulations of water elevations in the weathered Lavery till, unweathered Lavery till and the Kent recessional unit.

ENV502.06 Groundwater Monitoring Plan for the SDA at West Valley 19

This page intentionally left blank.

FRM002.07

Surface Water Monitoring Plan for the State-Licensed Disposal Area (SDA) at West Valley ENV504.01

Prepared by: Jean L. Williams

New York State Energy Research and Development Authority West Valley Site Management Program

West Valley, NY

04/01/2019 This page intentionally left blank 1 Purpose

The purpose of this Surface Water Monitoring Plan is to describe the requirements necessary for sampling, analyzing, assessing, and reporting the New York State Energy Research and Development Authority’s (NYSERDA) State-Licensed Radioactive Waste Disposal Area (SDA) surface water data in a manner that is technically sound, consistent with industry and regulatory guidance, and meets the reporting requirements in the SDA Part 380 permit.

2 Scope

NYSERDA’s 6 New York Code of Rules and Regulations Part 380 Permit for the SDA requires that surface water sampling results from four surface water monitoring locations (i.e., WNDCELD, WNFRC67, WNERB53, and WNNDADR) in stream channels bordering the SDA be reported to the New York State Department of Environmental Conservation in SDA quarterly and annual reports. In addition, one sample is collected at a background location (WFBCBKG), monitored to track ambient surface water concentrations for the same parameters monitored at the SDA surface water locations; and one annual sample is collected at a location approximately 1.5 miles north of the SDA on Buttermilk Creek (WFBCANL), where SDA-influenced groundwater daylights to become part of Buttermilk Creek surface water.

The four SDA surface water monitoring locations nearest to the SDA are situated to evaluate potential contaminant contributions to surface waters from the SDA and may also be impacted by adjacent West Valley Demonstration Project (WVDP) facilities. Two maps showing the showing the SDA surface water sampling locations are provided in Attachment A: Maps of SDA Surface Water Monitoring Locations. Figure 1 shows the four near-SDA surface water sampling locations (WNDCELD, WNFRC67, WNERB53, and WNNDADR), while Figure 2 shows the two additional surface water sampling points located away from the SDA (WFBCBKG and WFBCANL).

3 Quality Assurance (QA)

Program QA and quality control (QC), including data validation and verification, will incorporate, to the extent possible, the guidance, requirements and/or analytical methods identified in:

• Multi-Agency Radiological Laboratory Analytical Protocols Manual (MARLAPa) • HASL-300, Procedures Manual of The Environmental Measurements Laboratoryb • SW-846, Test Methods for Evaluating Solid Waste, Physical/Chemical Methodsc

Surface Water Monitoring Plan for the State-Licensed Disposal Area (SDA) at West Valley, ENV504.01 1 Additionally, analytical laboratories used to evaluate samples collected as part of this program must meet the New York State Department of Health Environmental Laboratory Approval Program (ELAP)- certification standards for analyses where ELAP certification is offered.

The specific analytes and contract required detection limits for surface water analyses are identified in Table 8-1 (see Section 8). The minimum detectable concentrations achieved for each analysis performed must be below the contract required detection limits and should be within the range identified by the specific analytical method used.

a Throughout this report, MARLAP refers to “Multi-Agency Radiological Laboratory Analytical Protocols Manual.” U.S. NRC. 2004. b DHS. 1997. “Procedures Manual of the Environmental Measurements Laboratory, HASL-300.” c EPA. 2014. “Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, SW-846.”

4. Precision and Accuracy

Precision and accuracy are dependent on adherence to standard operating procedures and analysis methods by both the contract laboratory and field sampling personnel. To assess the precision of the analytical laboratory and determine the impact of field sampling methods on the collected samples, periodic duplicate grab samples and matrix spike/matrix spike duplicate (MS/MSD) samples will be collected and analyzed as described in this section.

4.1 Field Precision and Accuracy

4.1.1 Field Precision

Field precision is dependent upon the sample collection process. Field precision will be controlled during sampling activities by adhering to the requirements of surface water sampling procedures.

Field duplicate samples allow sampling variation and laboratory performance to be evaluated by comparing analytical results of two samples collected from the same location at the same time. A duplicate sample will be collected from one SDA monitoring location and analyzed for all required parameters once every other calendar quarter. This sample will be collected and handled in the same manner and at the same time as the original sample. Field duplicate samples will be submitted blind to the laboratory and assigned a unique sample identification number. The calculated relative percent difference (RPD) or duplicate error ratio (DER) between the original and duplicate sample results is a measure of overall field and analytical precision. An RPD of ≤25 percent or a DER of ≤ 1.96 are acceptable for field precision.

Surface Water Monitoring Plan for the State-Licensed Disposal Area (SDA) at West Valley, ENV504.01 2 4.1.2 Field Accuracy

Field activities affecting accuracy will be assessed during sampling activities by assigned field staff. Field activities that affect accuracy will be assessed through observations and reviews of field logbooks and sampling logs to determine if field events are consistent with established sampling procedures. Deviations will be documented as to their extent, possible reasons, and the potential effect on data quality.

4.2 Laboratory Precision and Accuracy

4.2.1 Laboratory Precision

Laboratory precision and accuracy are evaluated through the use of both field and laboratory duplicate samples, laboratory control samples, and through calculating percent recovery for MS/MSD samples. Precision of the analytical results will be calculated by the laboratory. The calculated RPD or DER between the results for the MS and the MSD is a measure of the precision of the analytical method for the matrix. An RPD of ≤ 25% or a DER of ≤ 1.96 are acceptable for laboratory precision.

4.2.2 Laboratory Accuracy

MS/MSD samples are a laboratory QC check. MS/MSD samples will be prepared for tritium analysis annually in coincidence with SDA surface water samples. MS/MSD samples are prepared by first forming aliquots of the same sample in the laboratory. Known spikes are added at approximately 10 times the estimated minimum detectable concentrations to both aliquots, and each aliquot is then treated identically throughout the analytical method. The calculated MS/MSD recoveries are a measure of the accuracy of the analytical method for the environmental matrix being analyzed.

Accuracy of the analytical results shall be assessed by instrument calibration, calculating the percent recovery for laboratory control samples analyzed by the laboratory, calculating percent recovery for MS/MSD samples, and analyzing method and/or instrument blanks. The laboratory shall analyze the numbers and types of standards, laboratory control samples, MS/MSDs, and blanks specified by the analytical method, regulatory guidance, and ELAP-certification protocol.

Laboratory QA/QC data shall be available from the laboratory for a minimum of three years from the date of analyses for data verification and validation of SDA surface water sample results.

Surface Water Monitoring Plan for the State-Licensed Disposal Area (SDA) at West Valley, ENV504.01 3 5 Field Sampling and Support Protocols

5.1 SDA Surface Water Sample Locations

SDA surface water sampling locations are marked with identifying stakes in the field. The SDA surface water sampling locations are:

• WNDCELD - Located in Franks Creek just south of the SDA perimeter fence. This location is downstream and south of the WVDP Drum Cell prior to any inflow from the SDA. • WNFRC67 - Located in Franks Creek, east of the SDA. This location monitors potential impacts to Franks Creek from the SDA and is downstream of monitoring location WNDCELD. • WNERB53 - Located in Erdman Brook, north of the SDA and Nuclear Regulatory Commission- Licensed Disposal Area (NDA). This location monitors potential impacts to surface water from the northern portion of the SDA and areas within the WVDP, including the NDA. • WNNDADR - Located in Lagoon Road Creek between the NDA and SDA. This location monitors potential impacts to surface water from northwest and western areas of the SDA, and areas within the WVDP, including the NDA. • WFBCBKG - This background location is approximately 1.2 miles southeast of the SDA in Buttermilk Creek, just north of the creek’s intersection with Fox Valley Road, and upstream of any potential influences affecting surface water by either the WVDP or the SDA. • WFBCANL - Annual sampling location, approximately 1.5 miles north of the SDA on Buttermilk Creek. This location is downstream of where SDA-influenced groundwater daylights to become part of Buttermilk Creek surface water. 5.2 Sample Containers and Preservatives

To ensure the integrity of SDA surface water samples, the samples shall be collected in appropriate prepreserved containers as needed. Requirements for sample containers, preservation, and holding times shall be in accordance with MARLAP requirements for quality assurance project plans.

Containers used for surface water sample collection shall be certified precleaned to specifications found in MARLAP. The sample sizes, analytes, and appropriate preservatives shall be confirmed with the receiving laboratory before collection.

5.3 Sample Collection

Surface water samples shall be collected in accordance with NYSERDA’s procedures. Grab samples shall be collected to achieve a representative sample from the center of the flow, if possible. If flow at the designated location is not adequate for sampling, the field team shall choose a nearby location that is representative of the drainage and collection environment intended by that surface water location. Any nonroutine sample collection conditions that may affect the analysis shall be noted in the field logbook

Surface Water Monitoring Plan for the State-Licensed Disposal Area (SDA) at West Valley, ENV504.01 4 and/or sampling log.

5.3.1 Sample Identification

At a minimum, samples shall be labeled and identified in the field with the following information:

• sample identification (Sample ID - compatible with NYSIMSII database requirements and indicating surface water samples) • sample location identification (Sample Location ID - compatible with NYSIMSII database requirements) • sample date • required analyses 5.3.2 Field Conditions and Sample Documentation

Daily activities and observations shall be documented in a field logbook and/or the sampling log. Documentation must be sufficient to enable participants to accurately and objectively reconstruct events that occurred during the project. At a minimum, the following sampling information and field observations shall be recorded:

• location • date • time • sample identification information (as described in section 5.3.1) • type of sample (i.e., grab) • sample volume • preservatives • number of containers • QC samples • person performing sampling • chain of custody (COC) information (using COC forms) • weather conditions • wind direction • other remarks describing unusual circumstances or difficulties These records shall be retained by the contractor for a period of up to one year. All surface water sampling records shall be annually transferred to the West Valley Site Management Program (WVSMP). The WVSMP shall retain these records for five years from the date of sampling collection.

5.4 Surface Water Sampling Schedule

Table 5-1 summarizes the surface water sampling frequency and parameters. Each calendar quarter, one complete set of surface water samples, to be analyzed for gross alpha, gross beta, and tritium, shall be

Surface Water Monitoring Plan for the State-Licensed Disposal Area (SDA) at West Valley, ENV504.01 5 collected at each surface water location except for WFBCANL. In addition, one field duplicate sample shall be collected every other calendar quarter from a single selected location and one complete set of surface water samples shall be collected from WFBCANL annually.

Table 5-1. SDA Surface Water Sampling Summary

All samples are analyzed for gross alpha, gross beta, and tritium.

Source: NYSERDA

Location Frequency WNDCELD Quarterly WNFRC67 Quarterly WNERB53 Quarterly WNNDADR Quarterly WFBCBKG Quarterly Annually (in conjunction with second WFBCANL quarter sampling round)

6 Post Collection Sample Handling, Custody, and Shipment

Samples are to be handled, stored, prepared, and shipped in accordance with applicable NYSERDA procedures for field sample management.

6.1 COC

A COC shall be completed to maintain a record of sample collection, transfer between personnel, shipment, and receipt by the laboratory. The COC is used as physical evidence of sample custody. Each time the samples are transferred to another custodian, the party relinquishing and the party receiving the samples must sign, date, and record the time of transfer. A copy of the custody record shall be retained and maintained by the contractor with the sample event files until they are transferred to the WVSMP.

Shipping coolers shall be secured, and custody seals placed across cooler openings. COC shall also be documented while samples are in the possession of the contract laboratory. A completed COC record shall be forwarded with the analytical results to NYSERDA.

Surface Water Monitoring Plan for the State-Licensed Disposal Area (SDA) at West Valley, ENV504.01 6 6.2 Sample Packaging and Transport

Sample packaging and transport will be performed in a manner that protects the sample and complies with applicable regulations in 49 Code of Federal Regulations (U.S. Department of Transportation); and, for Federal Express shipments, the International Air Transport Association’s Dangerous Goods Regulations (most recent annual revision).

6.3 Documentation and Labeling

COC procedures will be used to ensure proper control of samples while in the field and during transport to analytical laboratories. The following forms, labels, and paperwork shall be used for sample management:

• prepared sample labels (as described in section 5.3.1) • field logbook • sampling logs • COC forms • airbills and/or bills of lading

7 Equipment Calibration and Maintenance

The operation and use of field equipment and instruments will be covered by specific procedures. These procedures shall be based upon accepted standard practice and/or equipment manufacturer's instructions. Field instruments shall be calibrated and/or performance-checked before use in accordance with the recommendations of the manufacturer. The field logbook shall be used to document pertinent equipment/instrument calibration, operation, and maintenance. Personnel using measuring and test equipment shall check the calibration status or calibrate the equipment before using it.

8 Analytical Methods and Detection Limits

The contract required detection limits for radioanalyses required to be performed on SDA surface water samples are included in Table 8-1. The analytical methods used by the laboratory to evaluate SDA surface water samples shall be ELAP-certified methods when ELAP certification is available for a specific parameter.

Surface Water Monitoring Plan for the State-Licensed Disposal Area (SDA) at West Valley, ENV504.01 7 Table 8-1. Parameters and Detection Limits

Source: NYSERDA

Parameter CRDL (pCi/L) Gross alpha 2E+00 Gross beta 2E+00 Tritium 2E+02

9 Data Reduction, Validation, and Reporting

Data reduction, validation, reporting, and other recordkeeping and documentation associated with processing samples through the given laboratory shall follow the requirements mandated by ELAP and applicable U.S. Environmental Protection Agency (EPA) guidance documents. Requirements for data reduction, validation, and reporting process control is described in MARLAP and applicable NYSERDA plans and procedures.

9.1 Reduction

Data reduction refers to computations and calculations performed on the data. Examples of data reduction include computing summary statistics, standard errors, confidence limits, averaging, assignment of reporting units, and model validation. Standard equations and approved procedures shall be used in the laboratory by persons performing the analyses and by persons verifying the data. Radiological data shall be reported with statistically supported limits of uncertainty to the 95 percent confidence interval. All data, when reported, shall be rounded to the number of significant figures consistent with the confidence limits.

Replicate measurements of a single sample shall be averaged before further data reduction. All documents pertinent to the analysis of NYSERDA’s samples shall be retained by the contract laboratory for a minimum of three years, and made available upon request for inspection or review.

9.2 Outlier Identification

Environmental field measurements can display a great deal of variability and any program of environmental measurement can produce numbers that lie outside the expected range of values. Documentation and validation of the cause of outliers shall accompany any attempt to correct or delete data values. Outlier values shall not be omitted from the raw data; however, these values shall be identified in the reporting of the analytical results as outliers.

Surface Water Monitoring Plan for the State-Licensed Disposal Area (SDA) at West Valley, ENV504.01 8 9.3 Validation

Data validation is the process by which a sample measurement, method, analytical result, or piece of data is deemed useful for a specified purpose. The data validation process consists of data reduction, review, certification, fitness qualification, and verification. Data validation shall be performed for 100 percent of the collected samples. Validation shall include a check of the COC, requested (as compared to reported) analyses, analysis holding times, MS/MSD analyses, duplicate analyses, internal standard results, surrogate recoveries, and any other method-specified QC criteria. Data validation process shall be consistent with MARLAP guidance and NYSERDA’s plans and procedures, and shall be documented by the contractor.

9.4 Reporting

A laboratory data validation report, consistent with MARLAP guidance, is required for all sample analysis data. The results of field QC samples shall be incorporated into the final data report. Requirements for the contents of the laboratory data report shall be specified in the contract with the approved analytical laboratory, and in the applicable contractor procedure(s) for data validation and verification.

Electronic copies of analytical laboratory reports and an electronic data file compatible with the NYSIMS database system import protocols and file structure shall be provided in addition to a signed, hard copy of the results.

Compiled analytical data, field logbooks, sampling logs, and COC records shall be provided to NYSERDA annually. NYSERDA shall maintain this information for not less than five years.

10 Records Administration

Records that shall be produced through execution of the surface water monitoring program include the following:

• surface water monitoring procedures, including health and safety requirements • field logbooks • sampling logs • COC documents • shipping and packaging records • data validation reports • analytical packages from the contract laboratory • SDA surface water reports • statistical assessment report

Surface Water Monitoring Plan for the State-Licensed Disposal Area (SDA) at West Valley, ENV504.01 9 • contractor training records SDA surface water data reports shall be provided to NYSERDA by the contractor quarterly and a statistical assessment of the surface water radioanalytical results shall be provided annually in accordance with NYSERDA’s plans and procedures. These reports will be maintained in the WVSMP’s central files for a minimum of five years.

11 Attachment

11.1 Attachment A, Maps of Surface Water Monitoring Locations (two pages).

Surface Water Monitoring Plan for the State-Licensed Disposal Area (SDA) at West Valley, ENV504.01 10

Attachment A – Maps of SDA Surface Water Monitoring Locations

Figure A-1. Surface Water Monitoring Locations near the SDA

Source: NYSERDA

Figure 2. Background and Annual Surface Water Monitoring Locations

Source: NYSERDA

A2 West Valley Site Management Program Page 1 of 12 ENVIRONMENTAL MONITORING PLANS 07/20/2015

TITLE: Sampling and Analysis Plan for Stormwater Discharge Monitoring at the State-Licensed Disposal Area (SDA) ENV505.01

1.0 PURPOSE

The purpose of this plan is to describe the requirements for sampling, analyzing, and processing SDA stormwater samples as well as reporting SDA stormwater data in a manner consistent with the SDA State Pollutant Discharge Elimination System (SPDES) permit. In addition, radiological parameters will be evaluated during stormwater sampling events as required by the Part 380 Radiation Control Permit for the SDA.

1.1 Sampling and Data Collection Procedures Stormwater samples will be collected in accordance with sampling procedures that assure compliance with the requirements of this plan, applicable New York State Department of Environmental Conservation (NYSDEC) and the U.S. Environmental Protection Agency (EPA) Stormwater Monitoring guidance, and the SDA SPDES permit. The culvert discharge point in Lagoon Road Creek, located on the northwest perimeter of the SDA (see Attachment A, Figure 1, location W01), will be the SDA stormwater sampling location under normal circumstances. However, the steps and methods described in this plan and the supporting stormwater sampling procedures can be used to monitor and sample stormwater at any designated SDA stormwater outfall (as shown in Figure 1, Attachment A), and identified in the SDA SPDES permit.

1.2 Organization and Responsibilities 1.2.1 NYSERDA Project Manager The New York State Energy Research and Development Authority (NYSERDA) Project Manager (PM) has overall management control for SDA stormwater monitoring activities, and reports directly to the SDA and Retained Premises Program Manager. The NYSERDA PM will ensure that stormwater sampling is performed in compliance with this Sampling and Analysis Plan (SAP) and applicable regulatory guidance. The NYSERDA Project Manager has specific responsibility for the following:  Maintaining this stormwater monitoring sampling plan.  Assuring that the safety and training requirements identified in contractor stormwater procedures are fully implemented.  Reviewing contractor procedures, records, and sample event information to assure compliance with regulatory requirements as well as accurate preparation of the Discharge Monitoring Report (DMR) forms for submittal to NYSDEC.  Preparing final submittal of DMR forms to NYSDEC.

ENV505.01 Page 2 of 12

1.2.2 Contractor PM (PM) The Contractor PM is responsible for ensuring that field personnel are deployed in response to an authorized and/or qualified storm event; and that sampling, analysis, validation, documentation and all other required activities are performed and reported to the NYSERDA PM in a manner consistent with the intent of this plan, EPA Stormwater Monitoring Guidance and the SDA SPDES permit. The Contractor PM is responsible for ensuring that the following training and field activities are performed:  Verifying that all sampling team members meet the training requirements for performing the assigned tasks.  In coordination with the NYSERDA PM, conducting pre-task briefings for the sampling team personnel, as needed, on the technical, quality control and safety requirements outlined in this plan, or the applicable contractor safety documentation.  Ensuring that all sampling materials and equipment are available and in good condition before sampling activities begin.  Ensuring that the sampling team has access to all applicable procedures, the procedures are the most current version, and that sampling activities are conducted in compliance with these procedures.  Maintaining a field logbook that summarizes the sampling team’s activities.  Identifying nonconforming activities or items, and corrective actions taken.  Documenting deviations from this plan or relevant procedures.  Reviewing all logbooks for accuracy and completeness, receiving the samples from the field, shipping the samples to the laboratory, and ensuring that chain-of-custody documentation is maintained.  Ensuring that laboratory data are reviewed, validated and reported as required by the SDA SPDES permit, this plan and associated procedures.

1.3 Training 1.3.1 Technical Training Only qualified, technical personnel that have had experience in collecting stormwater samples at the SDA will be assigned to stormwater sampling and analysis tasks. In addition, sampling team personnel should be familiar with the SDA sampling location to ensure quality sample collection as well as the procedures associated with their duties. 1.3.2 Safety Training Safety and training requirements associated with the implementation of this plan will be addressed during the WVSMP work planning process, and specified in stormwater sampling procedures.

2.0 QUALITY ASSURANCE

The following quality assurance (QA) objectives have been identified to comply with EPA stormwater sampling guidance, the requirements of “EPA Requirements for Quality Assurance Project Plans” and the Multi-Agency Radiological Laboratory Accreditation Program (MARLAP) guidance. Stormwater procedures will include relevant quality objectives identified in these guidance documents and the ENV505.01 Page 3 of 14

requirements of the New York State Department of Health (NYSDOH) Environmental Laboratory Accreditation Program (ELAP) for sample collection, handling and analytical methods.

2.1 Data Types and Uses The specific analytes to be measured are identified in the SDA SPDES and Part 380 permits, and are listed in Attachment B. Only ELAP-certified laboratories will be used to perform analyses. Minimum Detection levels (MDLs) for these parameters are determined by the laboratory’s performance of the specific EPA analytical method used. However, laboratory MDLs must meet or exceed NYSERDA contract reporting limits (CRLs) listed in Attachment B. In addition to analytical data, storm event measurements and the resulting flow from the sampled outfall must be collected in order to support the preparation of flow-weighted composite samples, and to prepare the DMR for submission to NYSDEC.

2.2 Internal QC Checks for Precision and Accuracy Precision and accuracy are dependent on adherence to sampling and analysis methods, the contract laboratory's Quality Assurance Plan and standard operating procedures. The evaluations discussed in this section will be implemented during each stormwater sampling round. 2.2.1 Field Precision and Accuracy 2.2.1.1. Field Precision Field precision will be controlled during all sampling activities by using trained, qualified sampling personnel, and by adhering to the requirements of the applicable stormwater sampling procedures. Field precision will be estimated using duplicate samples collected from the same stormwater outfall, and will be calculated for every constituent measured in the duplicate samples with results above the detection level. 2.2.1.2. Field Accuracy Field activities affecting accuracy will be assessed during sampling activities by assigned field staff. Field activities that can affect accuracy will be assessed through reviews of field logbooks and observations to determine if field events are consistent with established sampling procedures. All deviations will be documented as to the extent of and the reason for any deviations. Documentation will address the potential effect of a deviation on data quality. Sampling accuracy can also be assessed by evaluation of field blank results to determine if any inadvertent contamination was introduced during sampling events. One field blank per sampling event will be sent to the analytical laboratory for analysis along with the samples and will undergo the full suite of analyses.

2.2.2 Laboratory Precision and Accuracy 2.2.2.1. Laboratory Quality Assurance Plan and Procedures The contract laboratory's Quality Assurance Plan and standard operating procedures describe the methods within the laboratory to determine if the analytical process at the laboratory is “in control” at the time the stormwater samples were analyzed. Accuracy and precision for analytical methods are dependent upon the sample concentration, the analyte and the method itself. The anticipated accuracy and precision can be

ENV505.01 Page 4 of 12

found in the method description for each constituent to be analyzed. Procedures to be used by the analytical laboratory are those specified in EPA guidance and must be ELAP-certified. 2.2.2.2. Laboratory Precision Precision of the laboratory data will be measured through the use of the duplicate analyses on the same sample and will be calculated as the relative percent difference. 2.2.2.3. Laboratory Accuracy Accuracy of the chemical data will be assessed by calculating the percent recovery from matrix spike/matrix spike duplicate (MS/MSD) analyses and by quality control standards analyzed by the laboratory as a part of its internal Quality Assurance (QA)/Quality Control (QC) program (laboratory control samples and standard reference materials). The laboratory will calculate the percent recovery using the results from the MS/MSD analysis according to the analytical method. The laboratory will run the number and type of blanks and control samples specified by the analytical method to detect laboratory contamination and matrix bias. Laboratory QA/QC data will be available for a minimum of three years for data verification and validation of SDA stormwater sample results.

3.0 FIELD SAMPLING, MEASUREMENT AND SUPPORT PROTOCOL

The following section outlines the field-related activities to be conducted during stormwater monitoring at the SDA as required by the SDA SPDES permit. Stormwater monitoring will not be conducted if conditions are deemed unsafe by the NYSERDA PM.

3.1 SDA Site Stormwater Drainage Areas and Outfalls There are five SDA stormwater drainage areas located on the impermeable geomembrane cover. Each of the drainage areas are identical in runoff co-efficient and similar in drainage areas. Each of the SDA drainage areas flow into their respective drainage outfall (W01 - W05). Each outfall is hardened with rip-rap to mitigate the effects of erosion by stormwater. Stormwater at the SDA is not exposed to industrial activities or materials in any of the five SDA drainage areas. Industrial activities at the SDA are infrequent and occur inside of the buildings. Based on site history, maintenance and management practices, and knowledge of ongoing activities, stormwater drainage from any one of the five designated stormwater outfalls will be similar to the other four. Figure 1 (see Attachment A) shows the five SDA stormwater drainage outfalls.

3.2 Stormwater Sampling Schedule Stormwater sampling will occur as required by the SDA SPDES permit. As described in the permit and as required by NYSERDA, the following sampling schedule will apply:  Sampling will occur semiannually from SDA Outfall W01. Semiannual samples will be collected once between January and June, and again between July and December.  Sampling must occur during a qualified storm event as per EPA regulations. Samples should be collected from the discharge resulting from a storm event that meets the following criteria: o Greater than 0.1 inches. o At least 72 hours from the previously measurable (greater than 0.1 inches) storm event. ENV505.01 Page 5 of 12

o Where feasible, the variance in the duration of the event and the total rainfall of the event should not exceed 50 percent from the average or median rainfall event in the area. In the event a qualified storm event does not occur in the first three months of a semiannual period, the next significant rain event (0.1 inches or greater) will be sampled. Stormwater sampling data must be available for each semiannual period. Sampling results must be reported to NYSERDA no later than one week following the end of the monitoring period (i.e., by July 7 and January 7 for the two semiannual periods).

3.3 Sample Team Mobilization 3.3.1 Mobilization Criteria Sampling team mobilization will only occur when:  Weather conditions indicate the likelihood of a qualified storm event occurring at the SDA during daylight hours (Monday through Friday).  There are no adverse weather conditions that may potentially compromise the safety of the sampling team (i.e., high winds, electrical storms, etc.).  The storm is considered to be "qualifying," which is defined as no measureable amount of rainfall (0.1 inches within the previous 72 hours).  Variance in the total rainfall of the event does not exceed 50 percent from the average rainfall event in the area. To determine the average SDA rainfall event, the previous year’s average rainfall will be used. Due to the proximity of the West Valley Demonstration Project (WVDP) to the SDA, the prior year’s average rainfall, as documented in the WVDP Annual Site Environmental Report, will be used to determine when a rain event meets the 50 percent criteria, and is qualified as stated in EPA regulations. During the first three months of the semiannual period, the stormwater sampling team will not be mobilized within 72 hours of a storm event that resulted in more than 0.1 inch of rain. If sampling has not occurred in the first half of the semiannual period, attempts will be made to sample the next storm event capable of providing enough volume of stormwater for chemical analysis 3.3.2 False Starts and Stop/Start Rain Events False starts occur when the sampling team is mobilized but the rain event results in a nonqualifying event. False starts may also occur during storm events with intermittent rainfall that result in an inadequate precipitation volume to “qualify” in a reasonable amount of time or the event does not produce adequate flow in the outfall to collect the necessary sample volumes. In these cases, when inadequate sample volumes are collected due to the lack of flow in the outfall, the inadequate sample volume(s) must be discarded. If the rain event is a nonqualifying event but the volume of sample collected is adequate to perform the required analyses, the samples will be submitted for analysis and the data reported with an explanation that they are from a nonqualifying event.

3.4 Storm Event and Field Data Collection 3.4.1 Precipitation Data Storm event information will be collected from the SDA meteorological station. The meteorological station must be able to provide average or representative storm event data and provide adequate ENV505.01 Page 6 of 12

information to allow an assessment of whether a rainfall event may be representative as defined in the SDA permit. At a minimum, the duration of the storm event, the total amount of precipitation, and the number of hours between the storm event measured and the previous measurable (>0.1") storm event must be known and documented. 3.4.2 pH Data The pH and temperature of the stormwater discharge will be measured during the first 30 minutes (or as soon thereafter as practicable) of the storm event. Collection of pH data related to the rain event (as required by the SDA SPDES permit), will be accomplished by measuring the pH and temperature of rainwater collected in the vicinity of the sampling outfall during the first 30 minutes (or as soon thereafter as practicable) of the rain event. To assure adequate volume, more than one collection container (e.g., stainless steel pail) should be deployed. Collection containers will be free of fugitive dust and other contaminants that could buffer or otherwise affect the pH of the collected water. The same method used to measure the pH of the first flush sample will also be used to measure pH of the collected rainwater. Procedures describing the steps required to measure pH and temperature in both the rain event and the first flush samples are provided in the relevant field monitoring procedures. 3.4.3 Flow Data Collection of flow data related to the rain event will be made by measuring the height of water flowing through the drainage culvert or channel at the stormwater outfall. Flow measurement details are provided in the appropriate procedure and will include calculation of the total flow from the rain event and the maximum flow rate during the storm event. 3.4.3.1 Stage Height/Discharge Flow Relationships Stage height measurements, as determined by staff gauge readings or other method, taken over 15- to 20-minute time intervals for either the entire storm event or for the first three hours of the storm event, will be used to calculate the total flow. The relationships between stage height measurements and flow rates will be established prior to sampling to determine the instantaneous flow rate, and the periodic and total discharge from outfalls during a rain event. Periodic discharge rates are used to prepare the flow weighted composite samples by proportioning the volume of the individual sample aliquot used in the composite based upon the ratio of the periodic discharge to the total volume discharged. Graphs of the relationship between stage height and flow rate will be generated and available prior to collecting stormwater samples at the SDA. Graphs will be established using culvert data for diameter, length, slope and material. The resultant flow rates will be reported in cubic feet per second (CFS). Stage height and calculated flow rate relationships will be verified at the outfall prior to stormwater sampling. Graphs, calculations and associated verification data will be provided to NYSERDA in the stormwater sampling event report. 3.4.3.2 Preventive Maintenance Periodic evaluations of flow rate measurement equipment and techniques, including the performance of staff gauge measurements and the established relationship with flow rate, will be performed. This evaluation will serve to ensure that representative flow data are collected. Sediment that has accumulated in the vicinity of staff gauges shall be removed to allow flow readings to be taken under low flow conditions. ENV505.01 Page 7 of 12

3.5 Required Sample Types Analytical results will be generated for first-flush samples collected from the outfall during the first 30 minutes (or as soon thereafter as practicable) of discharge, and for flow-weighted composite samples collected over the first three hours or the entire event (if the event is less than three hours long), as required by the SDA SPDES permit. Nonradiological analyses are identified in Attachment B as well as the SDA SPDES permit; radiological parameters are identified in the SDA Part 380 permit and are also listed in Attachment B. 3.5.1 First-Flush Samples First-flush samples are “grab” samples collected from the outfall during the first 30 minutes (or as soon thereafter as practicable) of a storm event, and will generally contain the highest concentrations of pollutants that may have accumulated on drainage surfaces since the last storm event. Measurement of the pH and temperature will be collected from grab samples taken during the first 30 minutes of the storm event and should be conducted in the stormwater stream flow as soon as practical after the samples are collected. The results of these measurements will be recorded in the Contractor’s field logbook. 3.5.2 Flow-Weighted Composite Samples Flow-weighted composite samples are collected over the first three hours or the entire event (if the event is less than three hours long). Composite samples characterize the average quality of the stormwater discharge and provide the most accurate determination of the mass load of pollutants, if present. To prepare the flow-weighted composite sample, a minimum of three sample aliquots will be collected during each hour of the entire storm event for the first three hours of a storm event. The flow rate data collected over the duration of the storm event will be used to generate the instantaneous and total flow. The ratio of the flow during each sampling period compared to the total flow will be used to calculate the volume of each sample aliquot that will be used to make the composite sample. At least three sample aliquots must be collected each hour with at least 15 minutes between aliquot collections.

3.6 Sample Supplies, Reagents and Containers To ensure the integrity of SDA stormwater samples, all samples are collected in appropriate containers and preserved as needed. Requirements for sample containers, preservation, and holding times for the SDA stormwater program will be in accordance with laboratory requirements. Containers used for stormwater sample collection will be certified precleaned by the supplier. Adherence to these practices will provide pre-analysis documentation of sample container quality. The sample sizes, containers, preservation and holding times of these analytes will be confirmed with the receiving laboratory before actual collection. Sample containers will be prepared in advance of the sampling activities with appropriate preservatives. Precleaned container lot numbers and certificates of analysis should be maintained by the contractor for traceability.

3.7 Sample Collection 3.7.1 Overview Two samples will be analyzed from the designated stormwater outfall (W01): 1) a first-flush grab sample collected within the first 30 minutes of flow from the storm event (or as soon as practicable); and 2) a ENV505.01 Page 8 of 12

flow-weighted composite. The first priority for sampling is the collection of the first-flush grab samples. As soon as that sample set is completed, collection of the composite set of samples may begin. 3.7.2 Sampling Locations Figure 1 depicts the stormwater outfall locations. Unless otherwise directed by NYSERDA, Outfall W01 will be monitored during routine SDA stormwater sampling events. Outfall W01 is equipped with a permanent staff gauge that is used by the field crews in measuring flow and collecting time-aliquot samples for compositing. 3.7.3 Sample Identification At a minimum, samples shall be labeled and identified in the field as follows:  Sample Media (e.g., stormwater).  Sample Method (e.g., grab, composite, multiple container).  First-Flush Sample.  Composite Number (e.g., one through nine, corresponding to the hour of the storm event when the samples were collected).  Outfall location (e.g., W01). 3.7.4 Field and Sample Documentation The following information shall be recorded for each sample set at the time of collection:  Sample source (e.g., SDA), sample IDs, date/time of sampling.  Type of sample (e.g., grab or composite; and the volume and frequency of individual aliquots should be noted if a composite sample).  Person performing sampling and outfall ID.  Preservation method.  Comments.  Analyses required.  Sample volume and number of containers. In addition to information required above, detailed records of inspections, investigations, observations, chain-of-custody and all information pertinent to field sampling activities will be kept in a logbook designated for each outfall sampled, and on sample chain-of-custody forms. The information contained in the chain-of-custody and the field logbook for each outfall will be available upon request.

4.0 POST-COLLECTION SAMPLE CUSTODY, PRESERVATION AND SHIPMENT PROTOCOLS

Samples are to be handled, stored, prepared and shipped to the contract laboratories, and documented with a chain-of-custody form.

4.1 Documentation and Labeling The following forms, labels and paperwork are to be used for sample management: ENV505.01 Page 9 of 12

 Forms to record the exact location and any special sampling requirements associated with sample acquisition.  Prepared sample labels with the necessary sample ID and tracking information.  Sample shipment and chain-of-custody paperwork.

4.2 Chain-of-Custody To maintain a record of sample collection, transfer between personnel, shipment, and receipt by the laboratory, a chain-of-custody form is completed. The chain-of-custody form is used as physical evidence of sample custody. Each time the samples are transferred to another custodian, the party relinquishing and the party receiving the sample must sign, date and record the time of transfer. A copy of the custody form is retained and maintained with the sample event files. Shipping coolers are secured and custody seals are placed across cooler openings. The chain-of-custody shall be maintained while samples are in the possession of the contract laboratories. A completed chain-of-custody form shall be forwarded with the analytical results to NYSERDA.

5.0 EQUIPMENT CALIBRATION REQUIREMENTS

5.1 Field Equipment and Instrumentation Real-time field measurements (i.e., pH and temperature) will be made with calibrated instruments. The operation and use of field equipment will be covered by specific procedures. These procedures will be based upon ELAP requirements where applicable, accepted standard practice, and/or equipment manufacturer's instructions. Entries in the field logbook will be used to verify that field equipment was calibrated and documented before it is used, as appropriate. The field team leader is responsible for ensuring that equipment used by the sampling team is calibrated at the appropriate frequency. It is the responsibility of the personnel using the measuring and test equipment to check the calibration status or calibrate the equipment prior to use.

5.2 Contract Laboratory Equipment Off-site contract laboratories performing chemical analysis are required to participate in the ELAP program. All laboratories will be required to follow ELAP and EPA guidance protocols for the chemical and radiological analyses being performed. These protocols ensure that laboratory instruments are calibrated and operating properly so that data are both valid and traceable. The calibration program is documented as part of the laboratory’s QA/QC program.

6.0 DATA REDUCTION, VALIDATION AND REPORTING

Data reduction, validation, reporting, and other recordkeeping and documentation associated with processing samples through the given laboratory will follow the requirements mandated by ELAP-applicable NYSDEC and EPA guidance documents.

6.1 Reduction Data reduction refers to computations and calculations performed on the data. Examples of data reduction ENV505.01 Page 10 of 12

include: computing summary statistics, standard errors, confidence limits, averaging, assignment of reporting units and model validation. Standard equations and approved procedures will be used in the laboratory by persons performing the analyses and by persons verifying the data. Radiological data will be reported with statistically supported limits of uncertainty to the 95 percent confidence interval. All data, when reported, will be rounded to the number of significant figures consistent with the confidence limits. Confidence limits will be justified by the accuracy and precision of the analytical method. Replicate measurements of a single sample will be averaged before further data reduction. All documents pertinent to the analysis of NYSERDA samples shall be retained by the contract laboratory for a minimum of three years and made available upon request for inspection/reviews.

6.2 Outlier Identification Field variability of environmental field measurements can be great and any program of environmental measurement can produce numbers that lie outside the expected range of values. Documentation and validation of the cause of outliers will accompany any attempt to correct or delete data values. Outlier values will not be omitted from the raw data; however, these values will be identified in the reporting of the analytical results as outliers.

6.3 Validation Data validation is the process by which a sample measurement, method, analytical result, or piece of data is deemed useful for a specified purpose. The data validation process consists of data reduction, review, certification, fitness qualification and verification. Data validation will be performed for 100 percent of the collected samples. Validation will include: a check of the chain-of-custody, requested (compared to reported) analyses, analysis holding times, MS/MSD analyses, duplicate analysis, internal standard results, surrogate recoveries, and any other method-specified quality control criteria. Data validation will be consistent with EPA and MARLAP guidance, and conducted as described in the applicable contractor Standard Operating Procedure.

6.4 Reporting A laboratory data validation report, consistent with EPA and MARLAP guidance, is required for all sample analysis data. The results of all field QC samples will be incorporated into the final data report. Requirements for the contents of the laboratory data report will be specified in the contract with the approved analytical laboratory and in the applicable procedure(s) for data validation and verification. Validated data for each parameter will be reported in accordance with the SDA SPDES permit and NYSDEC’s DMR. An electronic data file compatible with the NYSIMSII database system import protocols and file structure will be provided, in addition to a signed, hardcopy of the results. Compiled analytical data, field logbooks, chain-of-custody forms and the storm event monitoring data will be provided and filed in the West Valley Site Management Program’s (WVSMP) Central Files.

7.0 DATA EVALUATION

Validated data packages will be used to evaluate the water quality of the stormwater discharge events sampled. If data are determined to be usable and representative of the discharge, the data will be ENV505.01 Page 11 of 12

submitted to NYSDEC on a completed DMR form. If the data are determined to be unusable or not representative of the discharge, then resampling and/or reanalysis will be considered. Data evaluation documentation will be provided with the SDA stormwater data report.

8.0 RECORDS ADMINISTRATION

Records that will be produced through execution of the stormwater discharge monitoring program are listed in the following table:

TABLE 1 - RECORD SCHEDULE

Source: NYSERDA Retained Retention Record Contents Created by by Period Stormwater Sampling Steps required to collect NYSERDA Contractor/ Five years Procedures stormwater samples at the NYSERDA SDA in compliance with the SDA SPDES permit & this plan. Stormwater Sampling Field Sampling Data Field Sampling Contractor/ Five years Log (Stormwater staff (e.g., NYSERDA Sampling Procedure) contractor) Outfall Field Logbook All field sampling activities, Field Sampling Contractor/ Five years data and comments. Storm staff (e.g., NYSERDA event data, equipment contractor) information, sample preparation & shipping notes. Stage height/flow rate Flow monitoring data Contractor Contractor/ Five years data/graphs/spreadsheet NYSERDA Precleaned container Container lot number Container Contractor Five years certification /certificates of analysis Supplier Chain-of-Custody Sample collection, transfer, Contractor Contractor/ Five years Forms shipment and receipt NYSERDA Shipping and packaging Carriers receipt for packages Contractor and Contractor/ Five years records and samples shipped shipping agent NYSERDA Data Validation Reports Laboratory data package and Contractor Contractor/ Five years w/ laboratory and field contractor assessments NYSERDA data SDA Stormwater Data Summary of data findings Contractor Contractor/ Permanent Report (including with completed DMR form NYSERDA NYSERDA completed DMR) and electronic data file. record Contractor technical Health and Safety training Contractor/ Permanent Contractor and health & safety records and IWPs NYSERDA NYSERDA NYSERDA training records (form only) record

ENV505.01 Page 12 of 12

9.0 ATTACHMENTS

Attachment A: Figure 1, SDA Stormwater Outfall Map (one page). Attachment B: Stormwater Effluent Monitoring Parameters (one page).

ATTACHMENT A

SDA Stormwater Outfall Map

This page intentionally left blank.

Figure 1. Stormwater Outfall Locations

Source: NYSERDA

Stormwater Outfall Locations Outfall Outfall

A-1

This page intentionally left blank.

ATTACHMENT B

SDA Stormwater Effluent Monitoring Parameters

This page intentionally left blank.

Stormwater Effluent Monitoring Parameters The SDA SPDES and Part 380 permits require sampling and analysis for the following parameters: On Site Rainfall  pH from on-site rainfall sample. Stormwater Outfall Discharge  pH from outfall stormwater.  Oil and Grease (limit of 15 mg/L)

 Biological Oxygen Demand - Five days (BOD5).  Chemical Oxygen Demand (COD).  Total Suspended Solids (TSS).  Nitrogen, Total (as N).  Phosphorus (Total).  Gross alpha.  Gross beta.  Gamma-emitting radionuclides by gamma spectroscopy.  Tritium. Storm Event Data  Duration of the storm event (in minutes).  Total precipitation for the storm event (in inches).  Number of hours between the storm event measured and the previous measurable (>0.1") storm event.  Maximum flow rate during the storm event.  Total flow from the rain event (in gallons) and a description flow measurement method. A NYSDOH Environmental Laboratory Approval Program (ELAP)-certified laboratory and EPA guidance methods must be used for stormwater sample analyses.

Analytes, Analytical Methodology Contract Reporting Limits (CRLs)

ANALYTE ANALYTICAL METHOD CRLs (µg/L) BOD5 EPA 405.1 2,000 pH EPS 150.1 SU TSS EPA 160.2 4,000 COD EPA 410.4 5000 Total N EPA 351.2 (TKN + nitrate + nitrite) 200 Oil and Grease EPA 1664 5,000 Phosphorus, Total EPA 365.2 or 365.4 50 Gross alpha/beta EPA 900 2.0E-9 μCi/mL Tritium EPA 906.0 2.0E-7 μCi/mL Gamma Spec (Cs-137) EPA 901.1 2.0E-8 μCi/mL

B-1 West Valley Site Management Program Page 1 of 3 ENVIRONMENTAL MONITORING PLAN 04/04/2012

SUBJECT: Environmental TLD Monitoring Program Plan for the State-Licensed Disposal Area (SDA) ENV506.01

1.0 INTRODUCTION

As part of the West Valley Site Management Program’s (WVSMP) environmental monitoring program for the SDA, environmental radiation levels are measured at SDA perimeter and select facility locations using thermoluminescent dosimeters (TLDs). These TLDs measure integrated gamma radiation absorbed from all sources at each SDA location throughout the calendar quarter.

2.0 DEFINITIONS

2.1 TLD - A card mounted with four chips (i.e., currently, two CaF 200 and two LiF 100 provided by Global dosimetry), labeled with unique identifiers supplied by the laboratory. The cards are then placed in an environmentally secure casing for field deployment. 2.2 Control Dosimeter - A TLD used to measure exposures extraneous to the measurement of interest. Exposures measured with control dosimeters are used to determine corrections to the exposure measurements of TLDs at field sites to isolate field-cycle exposures. 2.2.1 Laboratory Storage Control Dosimeter - A TLD used to account for the exposure a TLD will receive while being stored in the designated storage location. The storage location is generally a lead container (i.e., cave) located at or near the site of deployment or processing. The storage dose can be used to help derive contributions from storage to field and other control TLDs. 2.2.2 Transit Control Dosimeter - A TLD used to measure the exposure resulting from transportation of a batch of TLDs from the point of origin (i.e., laboratory) to the deployment site and back again. Typically, transit controls are stored in the on-site cave during the field deployment period, and returned to the laboratory with the exposed TLDs. 2.3 Exposure Cycle - The period between the pre-exposure annealing and the final readout of the phosphor (i.e., TLD chip). 2.4 Field Cycle - The period when the TLD is located at the field (also known as the deployment or monitoring period). 2.5 Field Site - Location in the environment where a TLD is placed to obtain the exposure measurement of interest.

3.0 QUALITY REQUIREMENTS

The program will include the following quality control and reporting requirements:  All activities will be conducted in accordance with the guidance in ANSI-N545-1975 and NRC Regulatory Guide 4.13. ENV506.01 Page 2 of 3

 Analytical laboratory vendors will be required to maintain qualifications and certifications to analyze the TLDs in accordance with the guidance of ANSI N545-1975 and NRC Regulatory Guide 4.13.  Annealing, calibration, readout and in-lab storage will be consistent with ANSI-N545-1975.  Each batch of TLD chips provided by the laboratory will be mounted in cards labeled with a unique identifier indicating the deployment period, location and dosimeter ID. The laboratory will then place these cards in an environmentally protected casing. The TLD batch will contain laboratory storage and transit control TLDs.  All reported data will be verified. Data qualifiers or limitations associated with the data will be reported.  The laboratory will perform laboratory quality control tests relevant to the TLD chips used for monitoring at the SDA.

4.0 MONITORING LOCATIONS

Environmental TLDs will be deployed at: three locations along the SDA perimeter for monitoring gamma radiation from all sources that may contribute to radiation levels within the SDA; and at one location with similar geographical characteristics and elevation levels (no greater than 150 meter difference in elevation) to determine natural background radiation levels. In addition, two control TLDs will be used to determine transit dose and laboratory storage dose contributions to the TLD batch. TLDs will be deployed at the following locations:  DNTLD33 - southwestern corner perimeter fence  DNTLD43 - western perimeter fence adjacent to the western access gate  DNTLD19 - eastern perimeter fence at (or near) the intersection of the SDA and West Valley Demonstration Project fences  DNTLD53 – northwestern corner perimeter fence  NYTLDBK- Background badge will be placed on the fence at the junction of Route 219 and Ashford Hollow Road  NYTLDTC - Transit control TLD to accompany the field TLDs during shipping  NYTLDLC - Laboratory Storage control to remain in the lead cave at the CH2MHILL B&W West Valley, LLC dosimetry lab The locations of SDA TLDs are shown in Figure 1 in Attachment 1. ENV506.01 Page 3 of 3

5.0 SURVEY FREQUENCIES

TLDs will be deployed at each monitoring location for one calendar quarter. Routine deployment of environmental TLD cards will be scheduled on the working day nearest the first day of the month for each quarter. The deployment date of TLD packages may be shifted a day or two to accommodate weather conditions, or optimize conditions for TLD storage and shipment.

6.0 REPORTING/RECORDS

The following records and reports will be provided to NYSERDA following each monitoring period:  Documentation of field deployment/retrieval for each TLD from time of receipt by the TLD vendor through return of exposed TLDs. This will include: individuals or carriers receiving the TLDs, date and time (or receipt), deployment and retrieval, field comments batch numbers and dosimeter IDs.  Laboratory data reports. Results will be reported with an associated uncertainty estimate to the 95 percent confidence level in units of milliRoentgen/Quarter.  Laboratory and contractor validation documentation.  Summary data report including data evaluation, qualification and assessment.  Electronic data file for importing into the NYSERDA’s NYSIMS II database system. Records received will be maintained in the WVSMP’s Central Files. Laboratory information related to the analysis of the TLD badges will be available upon request for a minimum of three years after the date of analysis.

7.0 REFERENCES

7.1 ANSI N545-1975, American National Standards Institute (ANSI), Performance, Testing and Procedural Specifications for TLDs (Environmental Applications), 1975. 7.2 NRC Regulatory Guide 4.13, U.S. Nuclear Regulatory Commission (NRC), Performance, Testing and Procedural Specifications for TLDs (Environmental Applications), 1977. 7.3 MARLAP, Multi-Agency Radiological Laboratory Accreditation Program, 2004. 7.4 EPA QA/G-8, Environmental Protection Agency (EPA) 2002, Guidance on Environmental Data Verification and Data Validation, 11/02.

8.0 ATTACHMENT

Attachment 1: SDA Environmental TLD Locations Map, one page.

This page intentionally left blank.

ATTACHMENT 1

SDA ENVIRONMENTAL TLD LOCATIONS MAP

This page intentionally left blank.

Figure 1: SDA Environmental TLD Locations

ENV506.01 A-1

This page intentionally left blank.

West Valley Site Management Program Page 1 of 8 SDA RADIATION PROTECTION PROCEDURES 10/28/2014

SUBJECT: Operation and Maintenance of Portable Radiation Detection Instruments SDA-RPP027.00

1.0 SCOPE

This procedure provides instructions for setup, source checks, operation, and shipping/receipt of portable radiation detection instruments for repair and calibration. For aspects of instrumentation operation not covered in this procedure, refer to the technical manual for that particular instrument, which are located in the West Valley Site Management Program’s (WVSMP) Central files.

2.0 PREREQUISITES

 Instruments shall have the efficiencies calculated to a four Pi geometry, and those efficiencies should be posted on the respective instrument.  The WVSMP’s Radiation Safety Officer (RSO) or designee will serve as the contact for source allocation for instrument set-up as well as response checks of instruments.  Sources shall be stored in a locked, flame retardant container, and posted and controlled in accordance with WVSMP Radiation Protection Program procedures.  All instruments will be logged out using the Instrument Tracking Log (Attachment A) prior to leaving the storage area for use in the field, then logged back in upon their return.  Instruments shall be surveyed to ensure that they do not contain any contamination prior to being returned to their designated storage area at the end of each work day/shift.

3.0 RESPONSIBILITY

3.1 WVSMP Contractors (e.g., Ecology and Environment, Inc.) WVSMP Contractors who are Radworker II trained can perform the following:  Field screening for investigating, segregating and labeling containers of used sampling equipment and other material staged in the pending analysis area of the T-1 Building.  Self frisking.  Notifying the WVSMP RSO of any instrument problems or erratic readings.  Returning instruments to WVSMP personnel at the end of the day.

3.2 WVSMP Personnel WVSMP personnel who are Radworker II trained and familiar with this procedure can perform all of the items identified in Section 3.1 as well as the following:  Preoperational checks for field use.  Field screening for investigation or verification purposes.  Removing instruments from service that fail the preoperational checks and notifying the WVSMP RSO.  Screening instruments for contamination prior to returning them from the field. SDA-RPP027.00 Page 2 of 8

3.3 WVSMP Radiation Protection Support Services Contractors WVSMP Radiation Protection Support Services Contractors who are Radworker II trained and familiar with this procedure can perform all of the items identified in Sections 3.1 and 3.2 as well as the following:  Quantitative field screening for conducting and documenting radiological surveys.  Minor maintenance or repairs to instruments with the concurrence of the RSO or designee.  Preparing instruments for shipping to calibration facilities.  Receipt, inspection, and set-up of instruments returning from calibration facilities.

3.4 WVSMP RSO or Designee The WVSMP RSO is responsible for and can perform all of the items identified in Sections 3.1 through 3.3 as well as the following:  Receipt, inspection, and set-up of all instrumentation.  Minor maintenance and repairs to instruments that do not require recalibration.  Investigating the reasons why instruments failed preoperational checks and initiating appropriate corrective actions.  Initiating repairs on, or acquiring replacements for, instruments removed from service.  Ensuring instruments are sent for calibration on their recommended cycle (e.g., annually).  Completing instrument set-up after calibration or major repair.  Training WVSMP personnel and Radiation Protection Support Services Contractors on the use of this procedure.

4.0 PROCEDURE

4.1 Preoperational Checks Perform the following instrument checks daily or prior-to-use, whichever is less frequent. These checks should be documented on the appropriate attachment located in a binder stored with or near the instruments.  Physical Condition: Perform a visual and operational check of the instrument to ensure that all parts and attachments are properly connected, and that the instrument will respond to the source. Consider the general physical condition of the instrument (e.g., look for missing knobs, inoperative switches, punctured windows, and/or damaged meter faces).

NOTE: If unsatisfactory results are obtained, contact the RSO or designee for further guidance.

 Calibration Check: Confirm that the instrument has been satisfactorily calibrated within its required calibration cycle (e.g., annually) by verifying that the calibration label is attached to the instrument, and is both current and legible.

NOTE: If unsatisfactory results are obtained, contact the RSO or designee for further guidance.

 Battery Check: If applicable, perform this check as outlined below or in accordance with the instrument's technical manual: SDA-RPP027.00 Page 3 of 8

. Position the appropriate selector switch to the "Batt" position or depress the "Batt Check" button with the instrument on. Observe the indication for the current battery condition. Typically, the current battery condition will be indicated by a meter deflection into the "Batt OK" region or "Batt OK" on the display. However, some instruments (e.g., Ludlum 2241-2), will have a flashing battery icon on the display when turned on, or will not function if batteries need replacing.

NOTE: If unsatisfactory results are obtained, refer to the technical manual for replacement of the batteries and repeat the check. The instrument shall display a satisfactory battery check prior to use.

 High Voltage Check: If applicable, verify that the high voltage is within the pre-established range or ±10 volts of the pre-established setting.

NOTE: If unsatisfactory results are obtained, contact the RSO or designee for further guidance.

 Background Check: This check is performed to verify that the instrument is responding within the normal parameters established during the set-up of the instrument. . For instruments with scaler capabilities (i.e., instruments with the ability to perform a time integrated count such as the Ludlum 2241-2 or 2929), perform a one-minute background count and verify that the results fall within ±20 percent of the previously established rate on the applicable instrument response test form. . For instruments without scaler capabilities (i.e., instruments that do not have the ability to perform a time integrated count such as the Thermo microrem dose rate meter or the Ludlum model 12 with NaI detector), allow the instrument sufficient time to stabilize (~15 seconds or when there is no more increase in the reading), then record the results. Verify that the results fall within ±20 percent of the previously established rate on the applicable instrument response test form.

NOTE: If unsatisfactory results are obtained, repeat the step for a maximum of two times. If the instrument still falls outside of the range, contact the RSO or designee for further guidance.

 Source Check: This check is performed daily or prior to use, whichever is less frequent, to verify the instrument response to a known source of radiation. Locate the source and the appropriate attachment for the instrument/detector, and perform the source check as described below: . For on-contact readings, verify that the source-to-probe geometry is reproducible, in direct contact and facing the probe. If not on contact, ensure the geometry is reproducible by utilizing a jig or source holder with demarcations for the distance and scale that is being checked. . For instruments with scaler capabilities, place the appropriate source in the geometry for that detector, and perform a one-minute count. . For instruments without scaler capabilities, place the appropriate source in the geometry for that detector and allow sufficient time for the instrument to stabilize for an accurate reading (~15 seconds or when there is no more increase in the reading). SDA-RPP027.00 Page 4 of 8

. Record the source check results on the appropriate attachment. . Verify that the results fall within ±20 percent of the previously established rate on the applicable instrument response test form.

NOTE: If unsatisfactory results are obtained, repeat the step for a maximum of two times. If the instrument still falls outside of the range, contact the RSO or designee for further guidance.

4.2 Survey Methodology This section provides basic guidance on the proper methodology for using the various types of radiation detection instrumentation. Refer to WVSMP applicable plans or procedures (e.g., Training and Instructions of Radioactive Material Users, Surveys and Survey Frequencies, etc.) for limiting conditions, action levels, responses or documentation of survey results. If there is a question or concern about readings obtained during a survey, consult the WVSMP RSO or designee for the proper actions to be taken. 4.2.1 Using Exposure Rate Instruments (survey instruments that read in R/hr, mR/hr, or R/hr) 4.2.1.1 General Area Surveys - Hold the detector at waist level with the most sensitive areas of the detector facing the item or areas being surveyed. Unless the radiation level on the item being surveyed is known, begin using the highest scale and work down the scales until the instrument reading is between 1/4 and 3/4 (mid-scale) scale, if possible. 4.2.1.2 Direct/Contact Surveys - Hold the detector within one centimeter (cm) from the surface of the item being surveyed. Contact reading should also be followed up with a 30 cm reading for posting and controlling purposes. 4.2.2 Using Beta-Gamma Survey meters (e.g., Ludlum 2241-2 with 44-9) 4.2.2.1 Counting Smears and Air Sample Filters - Hold the detector no further than 1/2 inch from the smear or filter. If the instrument has scaler capabilities, count the medium for one minute; otherwise, allow the instrument sufficient time to stabilize in counts (~15 seconds or when there is no more increase in the reading). 4.2.2.2 Direct surface scanning/Frisking - Hold the detector within 1/2 inch of the surface being scanned/frisked. Move the detector no faster than two inches per second, stopping when positive indication is noted from audio/visual response. Allow the meter indication to stabilize (~15 seconds or when there is no more increase in the reading), or perform a one-minute count.

4.2.3 Using Alpha Survey Meters (e.g., Ludlum 2241-2 with 43-92) 4.2.3.1 Counting Smears and Air Sample Filters - Hold the detector no further than 1/4 inch from the smear or filter. If the instrument has scaler capabilities, count the medium for one minute; otherwise, allow the instrument sufficient time to stabilize (~15 seconds or when there is no more increase in the reading). 4.2.3.2 Direct surface scanning/Frisking - Hold the detector within 1/4 inch of the surface being scanned/frisked. Move the detector no faster than two inches per second, stopping when positive SDA-RPP027.00 Page 5 of 8

indication is noted from audio/visual response. Allow the meter indication to stabilize (~15 seconds or when there is no more increase in the reading), or perform a one-minute count. 4.2.3.3 Survey of Instruments Upon Return From Use - Instruments shall be surveyed to ensure that they do not contain any contamination prior to being returned to the designated storage area at the end of each work day/shift, and the appropriate information shall be documented on the Instrument Tracking Log (Attachment A) for that instrument.  This survey should consist of a scan/frisk of the detector, cable and attached instrument box. If contamination is detected, contact the WVSMP RSO or designee for further guidance.

4.3 Shipping and Receiving of Instruments 4.3.1 Shipping of Instruments for Repair and Calibration  Remove the instrument from service and complete the appropriate information in the Instrument Tracking Log (Attachment A) for that instrument.  Survey the instrument and document the appropriate information on the Instrument Tracking Log. . This survey should consist of 100 percent direct frisk of the meter, cables, and probes as appropriate with both alpha and beta gamma detectors. If contamination is detected, perform 100 cm2 smears and count. If there is transferable contamination, control the instrument properly (i.e., bag it, tag it and perform contamination control processes), and notify the RSO or designee of the levels of contamination. If there is no transferable contamination, label the instrument as “Radioactive Material” and notify the RSO or designee.

NOTE: Do not ship instruments that are contaminated. The instrument will either need to be decontaminated to free release standards or shipped as radioactive material. Contact the RSO or designee for guidance.

 Instruments with delicate probe windows should have a probe cover secured over the instrument to prevent damage. Any special instructions should be included with the instrument.  Carefully package the instrument and ship it to the calibration facility. 4.3.2 Receipt of Repaired/Calibrated Instrument  If an instrument is returning from calibration, perform preoperational checks of the instruments in accordance with Section 4.1. If the instrument source check falls within ±10 percent of the previously established source check values, then the instrument may be returned to service; otherwise, perform a set-up and source check of the instrument using the appropriate source and attachments (see Section 4.6).  Place the date the instrument was returned to service on the Instrument Tracking Log (Attachment A) for that instrument.

4.4 Calibration Instruments used for monitoring radiological conditions shall be calibrated in accordance with WVSMP plans and procedures. SDA-RPP027.00 Page 6 of 8

 When an instrument has reached its calibration due date, the instrument shall be sent to an authorized calibration facility in accordance with Section 4.3, and the appropriate information recorded on the Instrument Tracking Log (Attachment A) for that instrument.

4.5 Minor Repair The following instrument repairs may be performed by qualified personnel in-house (i.e., without having to send the instrument out for calibration), provided the instrument passes the preoperational checks as specified in Section 4.1 once repairs are made  Cable replacement.  GM tube replacement.  Mylar replacement or repair.  Battery replacement.  Other minor repairs that do not involve the detector or instrument electronics (e.g., display glass replacement, handle replacement, etc.). Refer to the instrument’s specific technical manuals to perform the repairs and document all repairs on the instrument’s tracking log. Following the repairs, perform the preoperational checks as outlined in Section 4.1. If the instrument fails the checks, take it out of service and notify the RSO or designee so that arrangements can be made to have the instrument sent out for further repair and/or calibration. 4.6 Set-up of Instruments Instrument set-ups are performed to establish a site specific quality assurance check for each radiation detection instrument and are performed when new instruments are acquired, instruments are returned from repair and calibration, change in location for conducting prior to use instrument response checks, or as directed by the WVSMP RSO or designee. The following section provides guidance on how to perform instrument set-ups for the various types of instruments.

NOTE: For instruments with multiple detectors (e.g., model 2241-3), a separate set-up sheet may need to be completed for each detector used. Contact the RSO or designee for the appropriate sources to be used with each instrument/detector for set-up and response checks.

4.6.1 Instruments Used as Rate Meters with Auto-Scaling Capabilities (e.g., Ludlum 2241-2)  Perform a visual and operational check of the instrument to ensure that all parts and attachments are properly connected, and the instrument will respond to the source. If the instrument fails the visual inspection, remove from service, complete the Instrument Tracking Log (Attachment A), and notify the RSO or designee to obtain a replacement.  Complete the top of the Auto Scaling Instrument Set-up and Response Test Sheet (Attachment B).  Perform one, one-minute background count, or give the instrument time to stabilize (~15 seconds or when there is no more increase in the reading), then record the results on Attachment B.  Establish the background range as ±20 percent and record the results on Attachment B.  Perform a one-minute source count or give the instrument time to stabilize (~15 seconds or when there is no more increase in the reading), then record the results on Attachment B. SDA-RPP027.00 Page 7 of 8

 Calculate the source count range as ±20 percent and record the results on Attachment B. 4.6.2 Instruments Used as Rate Meters with Multiple Scales that Require Manual Switching (e.g., Thermo microrem, Ludlum Model 12).  Perform a visual and operational check of the instrument to ensure that all parts and attachments are properly connected, and that the instrument will respond to the source. If the instrument fails the visual inspection, remove it from service, complete the Instrument Tracking Log (Attachment A), and notify the RSO or designee.

NOTE: For instruments with multiple scales, it is important to check as many scales as possible with the sources available. This can be accomplished by using a source JIG with demarcations for the various scales or using multiple sources. Contact the RSO or designee for guidance.

 Complete the top of Multiscale Set-up and Response Test Sheet (Attachment C).  Establish the background rate by observing the display for ~15 seconds or until the instrument stabilizes (or when there is no more increase in the reading), then record the results on Attachment C.  Calculate the background range as ± 20 percent and record the results on Attachment C.  Establish the source rate by observing the display for ~15 seconds or until the instrument stabilizes (~15 seconds or when there is no more increase in the reading), then record the results on Attachment C. Attempt to get a reading between 20 to 80 percent of scale.  Calculate the source count range as ±20 percent and record the results on Attachment C.  Repeat the source set-up for each scale possible.

NOTE: For any areas on the attachments that are not applicable to the particular instrument being set-up or sourced check, indicate with N/A.

4.6.3 Dual Channel Instruments (e.g., Ludlum 2241-2)  Perform a visual and operational check of the instrument to ensure that all parts and attachments are properly connected, and that the instrument will respond to the source. If the instrument fails the visual inspection, remove from service, complete the Instrument Tracking Log (Attachment A), and notify the RSO or designee to obtain a replacement.  Complete the top of Dual Channel Scaler Instrumentation Set-up Sheet (Attachment D).  Perform 10, one-minute background counts for alpha and beta channels, then record the information on Attachment D.  Calculate the average background counts for both channels and record the information on Attachment D.  Calculate the background range as ± 20 percent from the average and record the information on Attachment D.  Perform 10, one-minute source counts for both alpha and beta channels, and record the information on Attachment D.  Calculate the average of the source counts and record the information on Attachment D. SDA-RPP027.00 Page 8 of 8

 Calculate the source count range as ± 20 percent from the average and record the information on Attachment D.  Include pertinent information from page one of Attachment D on page two, Dual Channel Scaler Response Test Sheet. 4.6.4 Single Channel Scaler Instrument (e.g., Ludlum model 12 with a 44-9 probe)  Perform a visual and operational check of the instrument to ensure that all parts and attachments are properly connected and the instrument will respond to the source. If the instrument fails the visual inspection, remove from service, complete the Instrument Tracking Log (Attachment A), and notify the RSO or designee to obtain a replacement.  Complete the top of Single Channel Scaler Instrumentation Set-up Sheet (Attachment E).  Perform 10, one-minute background counts and record the information on Attachment E.  Calculate the average of the background counts and record the information on Attachment E.  Calculate the background range as ± 20 percent from the average and record the information on Attachment E.  Perform 10, one-minute source counts and record the information on Attachment E.  Calculate the average of the source counts and record the information on Attachment E.  Calculate the source count range as ± 20 percent from the average and record the information on Attachment E.  Carry over pertinent information to the Single Channel Scaler Response Test Sheet, page two of Attachment E.

5.0 ACTION LEVELS FOR OPERATIONAL CHECKS If any of the following occur, the instrument should be removed from service and the RSO or designee notified:  Readings that deviate more than ±20 percent from reference source check readings.  Background readings that fall outside the pre-established range.  Unsatisfactory response battery check.  Unsatisfactory operation of instrument.

6.0 DOCUMENTATION

Completed forms will be reviewed and filed by the WVSMP RSO in the WVSMP Central files.

7.0 ATTACHMENTS

Attachment A: Instrument Tracking Log (one page). Attachment B: Auto Scaling Instrument Set-Up and Response Test Sheet (one page). Attachment C: Multiscale Set-Up and Response Test Sheet (one page). Attachment D: Dual Channel Scaler Instrumentation Set-Up and Response Test Sheet (two pages). Attachment E: Single Channel Scaler Instrumentation Set-Up and Response Test Sheet (two pages).

ATTACHMENT A INSTRUMENT TRACKING LOG

This page intentionally left blank. ATTACHMENT A

INSTRUMENT TRACKING LOG Model: Serial Number:

Inst. Date Tech Date Clean? Tech Out Initials Purpose In Y/N Initials

SDA-RPP027.00 Page A1 of 1 File: #

This page intentionally left blank.

ATTACHMENT B AUTO SCALING INSTRUMENT SET-UP AND RESPONSE TEST SHEET

This page intentionally left blank.

ATTACHMENT B

Auto Scaling Instrument Set-Up and Response Test Sheet

Date/Time: Inst. Model/SN#: Technician: Det. Model/SN#: Source Type: Units: Activity: High Voltage: Source ID: Background: Gross Source: BKG Range ± 20% Source Range ± 20% TO TO

HV Batt. Inst. Date Time ±10 volts: BKG Gross Source S/U Cal. Due S/U Technician

RSO or Designee Review/Date: ______S = Sat U = Unsat N/A = Not Applicable for this instrument

SDA-RPP027.00 Page B1 of 1 File #: 40101-_____

This page intentionally left blank.

ATTACHMENT C MULTISCALE SET-UP AND RESPONSE TEST SHEET

This page intentionally left blank.

ATTACHMENT C

Multiscale Set-Up and Response Test Sheet Inst. Model/SN#: Source Type: Date/Time: Det. Model/SN#: Activity: Technician: High Voltage: Source ID: Units: Background: BKG ± 20% TO

Scale 1 Scale 2 Scale 3 Scale 4 Scale 5 Source Gross: Source Range ± 20% To To To To To Geometry: (OW, CW, DISTANCE) RESPONSE TEST HV BATT Inst. Date Time Cal. Due S/U S/U BKG Scale 1 Scale 2 Scale 3 Scale 4 Scale 5 S/U Technician

RSO or Designee Review/Date: ______S = Sat U = Unsat N/A = Not Applicable for this instrument

SDA-RPP027.00 Page C1 of 1 File #: 40101-_____

This page intentionally left blank.

ATTACHMENT D DUAL CHANNEL SCALER INSTRUMENTATION SET-UP AND RESPONSE TEST SHEET

This page intentionally left blank.

ATTACHMENT D

Dual Channel Scaler Instrumentation Set-Up Sheet

Date/Time: Inst. Model/SN#: Technician: Det. Model/SN#: Source Type: High Voltage: Activity: Source ID:

1.0 Record 10, one-minute 2.0 Record 10, one-minute gross source counts bkgd counts for both  and  :  for both  and :     1 1 1 1 2 2 2 2 3 3 3 3 4 4 4 4 5 5 5 5 6 6 6 6 7 7 7 7 8 8 8 8 9 9 9 9 10 10 10 10

3.0 Calculate the average bkgd count: 4.0 Calculate the average source count:     5.0 Calculate the bkgd range (± 20%): 6.0 Calculate the source count range ± 20%):  to  to  to  to

RSO or Designee Review/Date: ______

SDA-RPP027.00 Page D1 of 2 File #: 40101-_____ ATTACHMENT D

Dual Channel Scaler Response Test Sheet Inst. Model/SN#: Source Type: Det. Model/SN#: Activity: High Voltage: Source ID:

 Background range (± 20%):  Source count range (± 20%): to to  Background range (± 20%):  Source count range (± 20%): to to

HV ±10  BKG  BKG  Gross  Gross Batt. Inst. Date Time volts Count Count Source Source S/U Cal. Due S/U Technician

RSO or Designee Review/Date: ______S = Sat U = Unsat N/A = Not Applicable for this instrument

SDA-RPP027.00 Page D2 of 2 File #: 40101-_____

ATTACHMENT E SINGLE CHANNEL SCALER INSTRUMENTATION SET-UP AND RESPONSE TEST SHEET

This page intentionally left blank.

ATTACHMENT E

Single Channel Scaler Instrumentation Set-Up Sheet

Inst. Model/SN#: Date/Time: Det. Model/SN#: Technician: High Voltage: Source Type: Activity: Source ID:

1.0 Record 10, one-minute bkgd counts: 2.0 Record 10, one-minute gross source counts: 1 1 2 2 3 3 4 4 5 5 6 6 7 7 8 8 9 9 10 10

3.0 Calculate the average bkgd count: 4.0 Calculate the average source count:

5.0 Calculate the bkgd range (± 20%): 6.0 Calculate the source count range (± 20%): to to

RSO or Designee Review/Date: ______

SDA-RPP027.00 Page E1 of 2 File #: 40101-_____ ATTACHMENT E

Single Channel Scaler Response Test Sheet

Inst. Model/SN#: Source Type: Det. Model/SN#: Activity: High Voltage: Source ID:

Background range (± 20%): Source count range (± 20%): to to

HV BKG Gross Batt. Inst. Date Time ±10 volts: Count Source S/U Cal. Due S/U Technician

RSO or Designee Review/Date: ______S = Sat U = Unsat

SDA-RPP027.00 Page E2 of 2 File #: 40101-_____ WYORK JEOF Department ORTUNITY. of Health

ANDREW M. CUOMO HOWARD A. ZUCKER, M.D., J.D. SALLY DRESLIN, M.S., R.N. Governor Commissioner Executive Deputy Commissioner MAY 1 8 2016

NYSERDA West Valley Site Management Program 10282 Rock Springs Road Box 191 West Valley, New York 14171

Attention: Douglas Coble Radiation Safety Officer

RE: NYS Dept. of Health Radioactive Materials License No. C0382 DH No. 16-160

Dear Mr. Coble:

Enclosed is Amendment No. 7 to New York State Department of Health Radioactive Materials License No. C0382, which names you as Radiation Safety Officer (RSO). As RSO, you are responsible for the day to day oversight of the radiation safety program. You need to be familiar with Part 16 of New York State Sanitary Code, Code Rule 38, and the conditions of the license, including documents incorporated by reference in Condition No. 11. This amendment also adds the letter dated March 1, 2016, signed by Paul J. Bembia, with attachments with updates to the WVSMP Organization Chart and license continuation pages.

If I may be of assistance, please contact this office at (518) 402-7590 or:

New York State Department of Health Bureau of Environmental Radiation Protection Radioactive Materials Section ESP, Corning Tower- Room 1245 Albany, New York 12237 Si~k

Desmond C. Gordon Associate Radiophysicist

DJS/DCG:ks

Enclosure: Amendment No. 7

Empire State Plaza, Coming Tower, Albany, NY 12237 I health.ny.gov NEW YORK STATE DEPARTMENT OF HEALTH

RADIOACTIVE MATERIALS LICENSE

Pursuant to the Public Health Law, Part 16 of the New York State Sanitary Code, Industrial Code Rule 38, and in reliance on statements and representations heretofore made by the licensee designated below, a license is hereby issued authorizing radioactive material(s) for the purpose(s), and at the place(s) designated below. The license is subject to all applicable rules, regulations, and orders now or hereafter in effect of all appropriate regulatory agencies and to any conditions specified below.

1. NAME OF LICENSEE 3. LICENSE NUMBER

FEIN 14-1731395 C0382

New York State Energy Research and 4. EXPIRATION DATE Development Authority (NYSERDA) West Valley Site Management Program August 29, 2022 (WVSMP) Phone (716) 942-9960

2. ADDRESS OF LICENSEE 5a. REFERENCE b. AMENDMENT NO.

10282 Rock Springs Road ·nH 16~160 7 West Valley, New York 14171

6. Radioactive Materials 7. Chemical and/or 8. Maximum quantity licensee (elements in mass number) physical form may possess at any one time

A. Radioactive wastes previously disposed of at the State Licensed Low Level Radioactive Waste Disposal Area (SDA) at West Valley.

9. Authorized use.

Possession as emplaced radioactive waste in the State Licensed Disposal Area (SDA); management and maintenance of the SDA, and possession and treatment of radioactive solids and liquids generated as a result of management and maintenance activities.

10. Licensed material shall be stored and used at the licensee' s installation located at the address indicated in Condition 2, above.

('0382_7 Page 1 of 3 NEW YORK STATE DEPARTMENT OF HEALTH

RADIOACTIVE MATERIALS LICENSE

3. License Number C0382 Sa. Reference DH 16-160 b. Amendment No. 1

11. Except as specifically provided otherwise in this License, the licensee shall conduct its program in accordance with the statements, representations and procedures contained in the documents, including any enclosures listed below. The Department's Regulations shall govern, unless the statements, representations and procedures in the licensee's application and correspondence are more restrictive than the Regulations.

A. License Renewal Request dated June 29, 2011, signed by Paul Bembia, with attachments.

B. Letter dated March 29, 2012, signed by Paul Bembia, Director, with attachments.

C. Letter dated April 18, 2012, signed by Paul Bembia, Director, with attachments.

D. Letter dated February 14, 2013, signed by Paul Bembia, Director, with attachments.

E. Letter dated March 1, 2016, signed by Paul J. Bembia, Director, with attachments.

12. A. The Radiation Safety Officer for this License is Douglas W. Coble.

B. Licensed material shall be used by, or under the supervision of, persons designated by the WVSMP Radiation Safety Officer.

C. The licensee shall maintain a complete and accurate record of the training and experience of each person permitted to use radioactive materials under this license.

13. The licensee shall instruct persons who engage in work under the license, in accordance with section 38.27(c) of Code Rule 38. Instruction shall include the licensee's operating and emergency procedures and other information contained in documents referenced in Condition 11 of the license.

14. The licensee shall have available appropriate instruments for radiation monitoring and analysis which shall be operational at all times, and calibrated before initial use and at subsequent intervals not exceeding twelve months in accordance with procedures contained in documents referenced in Condition 11 of the license.

C0382 7 Page 2 of 3 NEW YORK STATE DEPARTMENT OF HEALTH

RADIOACTIVE MATERIALS LICENSE

3. License Number C0382 Sa. Reference DH 16-160 b. Amendment No.1

15. A Personnel monitoring and bioassay requirements for SDA activities shall be determined by the WVSMP Radiation Safety Officer, using criteria contained in documents referenced in Condition 11 of the license.

B. Personnel monitoring devices issued pursuant to paragraph A of this condition for work to be performed at the SDA, shall only be worn at the SDA.

16. A The licensee shall notify the Department at least sixty (60) days prior to the loss of any services or equipment currently provided by its radiation protection support contractor.

B. The licensee remains responsible for the conduct of all work engaged in under the license regardless of who performs it, and for the radiation protection of all persons who enter upon the SDA site.

FOR THE NEW YORK STATE DEPARTMENT OF HEALTH

Date: MAY 1 8 2016 By_bJ ;MA,~ Daniel J.~HP, Chief DJS/DCG:ks Radioactive Materiais Section Bureau of Environmental Radiation Protection

C0382_7 Page 3 of 3 NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION

Division of Environmental Permits, Region 9 270 Michigan Avenue, Buffalo, NY 14203-2915 P: (71 6) 851-7165 I F: (716) 851-7168 www.dec.ny.gov

January 15, 2020

Mr. Paul Bembia NYS Energy Research and Development Authority West Valley Site Management Program 9030-B Route 219 West Valley, New York 14171-9500

Dear Mr. Bembia:

PERMIT TRANSMITTAL LETTER WNY NUCLEAR SERVICE CENTER RADIATION CONTROL PERMIT RENEWAL DEC ID#9-0422-00011/00011

Enclosed is your permit which was issued in accordance with applicable provisions of the Environmental Conservation Law. The permit is valid for only that project, activity or operation expressly authorized.

The DEC permit number and Program ID number, if applicable, should be retained for your records and should be referenced on all future correspondence and applications related to the permit. If modifications are desired after permit issuance, you must submit the proposed revisions and receive written approval from the Permit Administrator prior to initiating any change. If the Department determines that the modification represents a material change in the scope of the authorized project, activity, operation or permit conditions, you will be required to submit a new application for permit.

Please note the expiration date of the permit. Applications for permit renewal should be made well in advance of the expiration date (minimum of 90 days) and submitted to the Regional Permit Administrator at the above address.

Please review all permit conditions carefully. In particular, identify your initial responsibilities under this permit in order to assure timely action if required. Since failure to comply precisely with permit conditions may be treated as a violation of the environmental conservation law, you are requested to provide a copy of the permit to the project contractor, facility operator, and other persons directly responsible for permit implementation (if any).

~ ~0RK IDepartment of POln'u0 Nrrt Environmental 4 Conservation Mr. Paul Bembia January 15, 2020 Page 2 of 2

If you have any questions regarding this letter or the permitting process, please contact Lisa M. Czechowicz of my staff at 716/851-7165. Please contact Mr. Kenneth Martin or Mr. Patrick Conc.annon at 716/851-7220 if you have any technical questions regarding the permit conditions.

Respectfully,

David S. Denk Regional Permit Administrator

DSD/lmc

Ecc: Capt. Beth Haag, NYSDEC Division of Law Enforcement Mr. Kenneth Martin, NYSDEC, Division of Materials Management, Region 9 Mr. Patrick Concannon, NYSDEC, Division of Materials Management, Region 9 Ms. Anne Marie Gray, NYSDEC, Division of Environmental Remediation, Albany Mr. Timothy Rice, NYSDEC, Division of Materials Management, Albany Ms. Andrea Mellon, NYSERDA, West Valley Site Management Program Manager Mr. Douglas Coble, NYSERDA, Radiation Safety Officer Ms. Moira Maloney, United States Department of Energy Ms. Jennifer Dundas, United States Department of Energy NEW YORK STATE DEPARTMENT OF ENVIRONMENT AL CONSERVATION Facility DEC ID 9-0422-00011

PERMIT Under the Environmental Conservation Law

Permit Issued To: Facility: NYS ENERGY RESEARCH & DEVELOPMENT WESTERN NEW YORK NUCLEAR SERVJCE AUTHORJTY CENTER 17 COLUMBIA CIR 10282 ROCK SPRINGS RD ALBANY, NY 12203-6399 WEST. VALLEY.. NY 14171-9799 (518) 862-1090

Radiation Permitting Facility Owner Contact: Radiation Safety Officf!r: ANDREA MELLON DOUGLAS COBLE WESTERN NEW YORK NUCLEAR SERVICE WESTERN NEW YORK NUCLEAR SERVICE CTR CTR 10282 ROCK SPRJNGS RD 10282 ROCK SPRJNGS RD WEST VALLEY, NY 14171-9799 WEST VALLEY, NY 14171-9799 (716) 942-9960 (716) 942-9960

Facility Location: in ASHFORD in CATTARAUGUS COUNTY Facility Principal Reference Point: NYTM-E: 199.971 NYTM-N: 4705.969 Latitude: 42626'52.8-" Longitude: 78°38'53.7" Authorized Activity: Monitoring and maintenance of the State-Licensed Dispos<1I Area (SDA), a former low level radioactive waste burial site, for the purpose of maintaining site integrity to .control discharges and minimize the potential for release of radioactive materials to the environment The SDA is part of the Western New York Nuclear Service Center. This permit replaces all previous conditions and modifications of the Part 380 SDA Land Burial Facility Monitoring and Maintenance Permit in their entirety.

Permit Authorizations

Radiation Control - Under Articles 1, 3, 17, 19, 27 & 37 Permit ID 9-0422-00011/00011 Renewal Effective Date: 1/15/2020 Expiration Date: 1/14/2025

Page 1 of7 NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION Facility DEC ID 9-0422-00011

NYSDEC Approval

By acceptance of this permit, the permittee agrees that the permit is contingent upon strict compliance with the ECL, all applicable regulations, and all conditions included as part of this permit.

Permit Administrator: LISA M CZECHOWICZ, Deputy Regional Permit Administrator Address: NYSDEC Region 9 Headquarters 270 Michigan Ave Buffalp, NY 14203 -2915

Authorized Signature: ,I Date J I I I cJ-CQ._Q c*-..So , 1YJ . C3 ci \lMJ .j - - c;- --

Distribution List

ANDREA MELLON DOUGLAS COBLE Law Enforcement KENNETH G MARTIN PATRICK CONCANNON TIMOTHY B RICE ANN MARIE GRAY Paul Bembia, NYSERDA Moira Maloney, USDOE Jennifer Dundas, USDOE

Permit Components

RADIATION CONTROL PERMIT CONDITIONS

GENERAL CONDITIONS, APPLY TO ALL AUTHORIZED PERMITS

NOTIFICATION OF OTHER PERMITTEE OBLIGATIONS

Page 2of7 NEW YORK STATE DEPARTMENT OF ENVJRONMENTAL CONSERVATION e Facility DEC ID 9-0422-00011

RADIATION CONTROL PERMIT CONDITIONS

1. Monitoring & Maintenance of SDA Except as specifically provided otherwise in this permit, monitoring and maintenance activities for the SDA must be performed in accordance with the statements, representations and procedures contained in the documents listed in Radiation Control Permit (RCP) Condition 2, including any enclosures and those listed below:

Letter dated July 9, 2019 from Paul Bembia to David Denk ''Request to Renew Radiation Control Permit #137-6, NYSDEC Permit Number 9-0422-00011/00011" and the enclosure "Radiation Control Permit Renewal Application for the State-Licensed Disposal Area"

The New York State Department of Environmental Conservation 6 NYCRR Part 380 regulations shall govern unless the statements, representations and procedures in the application and correspondence are more restrictive than the regulations.

2. Revision Approvals Any revisions of the documents listed below must be submitted to the Department for review and written approval prior to implementation. Approval of a revision to any of these documents shall supersede all prior versions of that document.

"Site Description for the New York State-Licensed Disposal Area (SDA)" dated 6/19/19 "SDA Building Description" OPS505.04, dated 8/21/19 "SDA Infiltration Controls Description" OPS508.03, dated 6/19/19 "Groundwater Monitoring Plan for the State-Licensed Disposal Area {SDA) at West Valley" ENV502.06, dated 6/19/19 "Leachate Monitoring Plan for the State-Licensed Disposal Area (SDA)" ENV501.06, dated 6/19/19 "Security Plan for the l/INSMP" OPS503.06, dated 6/19/19 "Effluent Minimization Program for the West Valley Site Management Program" SDA-RPP023.02, dated 6/19/19 "Regulatory Reporting Requirements for Routine SDA Reports," dated 13/28/02 "Emergency Response_ Plan for the State-Licensed Disposal Area" ER 100.1 D, dated 6/19/19 Note: Changes to Appendix C-1 "NYSERDA Emergency Contact List" are not subject to implementation. Any such changes must be submitted to the Department for inclusion in the Emergency Plan. "Erosion Monitoring Plan (EMP)" ENV509.02, dated 6/19f19 "Erosion Control and Maintenance Plan" OPS511.02, dated 6/19/19

Changes to the above plans and procedures including, but not limited to, changes in administration, contact names or telephone numbers may be deemed administrative changes and may not necessitate a modification of this permit. Upon the discretion of the Department significant changes to any of the documents listed above may necessitate a permit modification. Revisions to related plans, procedures, or descriptions provided in documents not listed above must be reported to the Department within 30 days of their implementation.

3. Security Requirements New York State Energy & Research Development Authority {NYSERDA) must provide security for the SDA sufficient to: (a) control access to, and use of, the SDA at an times, {b) minimize the potential for the inadvertent or unauthorized entry of persons or animals onto the SDA, and (c) prevent unauthorized removal of radioactive materials from the SDA.

4. Security Measures NYSERDA must provide security measures for the SDA that, at a minimum, must include: {a) a fence or other barrier that completely surrounds the SDA and is capable of preventing unauthorized entrance, {b) a means to control entry at all times, through gates or other entrances to the SDA, {c) a vehicle(s) for accessing, patrolling, and controlling the SDA, (d) a means of detecting intruders.

Page 3 of7 NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION e Facility DEC ID 9-0422-00011 -

(e) a means of response to an intruder sufficient to prevent any potential intrusion into, or breaching of, the waste disposal trenches, and (f} signs at each entrance to the SDA that are legible from a minimum distance of 25 feet which contain a warning that entry is permitted only for properly trained or escorted individuals, and that radioactive waste is present at the SDA.

5. Radioactive Material Releases While there are no anticipated releases of radioactive material to the environment, any such releases must be maintained as low as reasonably achievable. Any radioactive material released to the environment from the SDA must not result in a total effective dose equivalent exceeding 25 millirem per year to a member of the public.

6. Retention/Preservation of All Records NYSERDA must retain and preserve all records now in its possession that pertain to SDA burial operations conducted during the period of active disposal {1963-1975).

7. Maintain Records for Containment of Waste NYSERDA must retain all records generated for the purpose of containment of wastes within the SDA, preventing inadvertent intrusion, detecting releases from the trenches, emergency response, or site security, until such time as the Department determines that a permit is no longer required for the SDA.

8. Transfer of Records Prior to Permit Termin-ation Prior to termination of the permit, all records required to be retained by Part 380 or the conditions of this permit must be transferred to the Radioactive Materials Management Section and Region 9 of the Department, at the addresses listed in RCP Condition 13 below.

9. Provide Copies of Records Upon request, NYSE RDA must submit, within a time frame specified by the Department, copies of records required to be kept by Part 380, this permit, and any relevant information needed by the Department to determine compliance with the permit.

10. Requests for Temporary Changes to Monitoring & Inspection The Department will entertain requests from NYSERDA for temporary changes to required monitoring and inspection activities. Department approval of such requests will take the form of an approval letter. All such requests- must satisfy the following criteria:

(a) The specific monitoring or inspection condition for which a temporary change is being requested is clearly described. This description must include reference to the special cdndition number, or approved site plan or procedure, as it appears in the permit. (b) The reason for the request is clearly detailed. The only acceptable reasons are those that address health and safety concerns, or circumstances where site monitoring and maintenance activities could not be performed safely or effectively if performed as specified in the permit (c) The time period for which the change is being requested is clearly defined and is limited to only the amount of time necessary to accomplish the task described, and must not extend beyond the period of time when the hazard prompting the request exists. (d) Every reasonable effort has been made to identify alternative means for meeting the requirement for which a temporary change is being requested. The options reviewed during this process must be described in the request and the reasons for accepting or rejecting each one summarized.

11. Aliquots of Samples Upon Department request, NYSE RDA must provide aliquots (splits) of any monitoring or confirmatory samples collected, provide_d that adequate sample volume exists.

12. Storm Water Runoff Sample Collection NYSERDA must collect samples of storm water runoff from the exposed geomembrane cover on the SDA and analyze them by gamma spectroscopy and for gross alpha and gross beta, and Tritium {H-3) content. These samples are to be collected at the sampling frequency and locations specified in the SDA State Pollutant Discharge Elimination System Permit. Samples are to be handled and data is to be processed as described in the NYSERDA procedures that support environmental monitoring at the SDA.

Page 4 of7 NEW YORK ST ATE DEPARTMENT OF ENVIRONMENT AL CONSERVATION Facility DEC ID 9-0422-00011

13. Quarterly and Annual Report Submissions NYSERDA must submit quarterly and annual reports as specified in Regulatory Reporting Requirements for Routine SDA Reports referenced in RCP Conditon 2 above.

(a) The quarterly reports must also include the data generated to satisfy Condition 12 above, including the required comparison with background concentrations. (b) The annual report must also include: {i) the results of walkover inspections, and {ii) the annual elevation survey of the North Slope of the SDA. (c) The annual report must also Include the following information collected pursuant to the Erosion Monitoring {EM) Plan: (i) quantitative measurements of erosion ff!atures, as defined in the EM Plan, (ii) photographs, as defined in the EM Plan, and (iii) any updates to the topographic map of the land surtace of the SDA and adjacent slopes and stream channels as required by the EM Plan.

All reports must be submitted to:

Radioactive Materials Management Section NYS Department of Environmental Conservation Division of Materials Management 625 Broadway Albany, NY 12233-7255

-and-

NYS Department of Environmental Conservation Division of Materials Management, Region 9 Regional Environmental Quality Engineer 270 Michigan Ave Buffalo, NY 14203-2915

14. Report of Significant Erosional Impacts NYSERDA must report any significant erosional impacts to the SDA, the surrounding slopes (including any survey results showing changes in the north slope elevations indicative of the slope instability, defined as greater than 6 inches of elevation change since the last survey) or the adjacent streams. This information must be transmitted by phone to the Radioactive Materials Management Section at (518) 402-8789 and to the Regional Materials Management Engineer at (716) 851-7220 within one (1) business day. A written report of such an event must be submitted to the addresses listed in RCP Condition 13 within 30 days.

GENERAL CONDITIONS - Apply to ALL Authorized Permits:

I. Facility Inspection by The Department The permitted site or facility, including relevant records, is subject to inspection at reasonable hours and intervals by an authorized representative of the Department of Environmental Conservation (the Department) to determine whether the permittee is complying with t11is permit and the ECL. Such representative may order the work suspended pursuant to ECL 71- 0301 and SAPA 401(3).

The permittee shall provide a person to accompany the Department's representative during an inspection to the permit area when requested by the Department.

Page 5 of7 NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION Facility DEC ID 9-0422-00011

A copy of this permit, including all referenced maps, drawings and special conditions, must be available for inspection by the Department at all times at the project site or facility. Failure to produce a copy of the p_ermit upon request by a Department representative is a violation of this permit.

2. Relationship of this Permit to Other Department Orders and Determinations Unless expressly provided for by the Department, issuance of this permit does not modify, supersede or rescind any order or determination previously issued by the Department or any of the terms, conditions or requirements contained in such order or determination.

3. Applications For Permit Renewals, Modifications or Transfers The permittee must submit a separate written application to the Department for permit renewal, modification or transfer of this permit. Such application must include any forms or supplemental information the Department requires. Any renewal, modification or transfer granted by the Department must be in writing. Submission of applications for permit renewal, modification or transfer are to be submitted to:

Regional Permit Administrator NYSDEC Region 9 Headquarters 270 Michigan Ave Buffalo, NYl4203 -2915

4. Submission of Renelval Application The permittee must submit a renewal application at least 90 days before permit expiration for the following permit authorizations: Radiation Control.

s. Permit Modifications, Suspensions and Revocations by the Department The Department reserves the right to exercise all available authority to 1nodify, suspend or revoke this permit. The grounds for modification, suspension or revocation include:

a. materially false or inaccurate statements in the permit application or supporting papers;

b. failure by the permittee to comply with any terms or conditions of the permit;

c. exceeding the scope of the project as described in the permit application;

d. newly discovered material information or a material change in environmental conditions, relevant technology or applicable law or regulations since the issuance of the existing permit;

e. noncompliance with previously issued permit conditions, orders of the commissioner, any provisions of the E_nvironmental Conservation Law or regulations of the Department related to the permitted activity.

6. Permit Transfer Permits are transferrable unless specifically prohibited by statute, regulation or another permit condition. Applications for permit transfer should be submitted prior to actual transfer of ownership.

Page 6 of7 NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION Facility DEC ID 9-0422-00011

NOTIFICATION OF OTHER PERMITTEE OBLIGATIONS

Iteni A: Permittee Accepts Legal Responsibility and Agrees to Indemnification The pennittee, excepting state or federal agencies, expressly agrees to indemnify and hold hannless the Department of Environmental Conservation of the State of New York, its representatives, employees, and agents ("DEC") for all claims, suits, actions, and damages, to the extent attributable to the pennittee's acts or omissions in connection with the permittee's undertaking of activities in connection with, or operation and maintenance of, the facility or facilities authorized by the pennit whether in compliance or not in compliance with the tenns and conditions of the pennit. This indemnification does not extend to any claims, suits, actions, or damages to the extent attributable to DEC's own negligent or intentional acts or omissions, or to any claims, suits, or actions naming the DEC and arising under Article 78 of the New York Civil Practice Laws and Rules or any citizen suit or civil rights provision under -federal or state laws.

Item B: Permittee's Contractors to Comply with Permit The permittee is responsible for informing its independent contractors, employees, agents and assigns of their responsibility to comply v.rith this permit, including all special conditions while acting as the permittee's agent v.rith respect to the permitted activities, and such persons shall be subject to the same sanctions for violations of the Environmental Conservation Law as those prescribed for the permittee.

Item C: Permittee Responsible for Obtaining Other Required Permits The permittee is responsible for obtaining any other permits, approvals, lands, easements and rights-of way that may be required to carry out the activities that are authorized by this permit.

Item D: No Right to Trespass or Interfere with Riparian Rights This permit does not convey to the permittee _any right to trespass upon the lands or interfere with the riparian rights of others in order to perform the permitted work nor does it authorize the impairment of any rights, title, or interest in real or personal property held or vested in a person not a party to the permit.

Page 7 of7 New .York State Department of Environmental Conservation Division of Environmental Permits NYSDtCHEADQUARTERS 625 BROADWAY ALBANY, NY 12233 (518) 402-9167 SPDES PERMIT RENEWAL 8/11/2015

CHRIS ANDRZEJEWSKI Permittee Name: NYS ENERGY RESEARCJI & WNY NUCLEAR SERVICES CTR DEVELOPMENT AUTHORITY 10282 ROCK SPRINGS RD Facility Name: WESTERN NEW YORK NUCLEAR WEST VALLEY NY 14171 SERVICE CE!lnER Ind. Code: 9511 County: CATTARAUGUS DEC ID: 9-0422-00011/02001 SPDES No.: NY0269271 Permit Effective Date: ll/l/2015 Permit Expiration Date: 10/3112020

Dear Permittee, The State Pollutant Elimination System (SPDES) permit renewal for the facility referenced above is approved with the new effective and expiration dates. This letter together with the previous valid permit for this facility effective on 1110l/2010 and any subsequent modifications constitute authorization to discharge wastewater in accordance with all terms, conditions and limitations specified in the previously issued permit(s).

As a reminder, SPDES permits are renewed at a central location in Albany in order to make the process more efficient. All other concerns with your permit, including applications for permit modification or transfer to a new owner, a name change, and other questions, should be directed to: Regional Permit Administrator NYSDEC Region 9 Headquarters 270 Michigan Ave Buffalo, NY 14203-2915 (716) 851-7165 If you have already filed an application for modification of your permit, it will be processed separately by that office.

If you have questions concerning this permit renewal, please contact LINDY SUE CZUBERNAT at (518) 402- 9167. Sincerely, ~ rn.~ ~ Stuart M. Fox Deputy Chief Permit Administrator cc: RPA RWE BWP BWC File EPA - :New Yo'rk State Department of Environmental Conservation Division of Environmental Permits, Region 9 270 Michigan Avenus, Buffalo, New York, 14203-2999 Phone: (71 6) 851-7165 • FAX: (716) 851-7168 vU-: ~, pJf' . Website: www.dec.state.ny.us pjb, h'IJw' -... ~ September 28, 2005 H~ D<>nlse M. Sheehan f.1e (()r'j·) Acting Ccm.tnieskiner C. L. Gerwitz, Program Manager New York State Energy Research and Development Authority 10282 Rock Spring Road SEP 2005 West Valley, New York 14171 RECEIVED ... Dear Permlttee: NYSE RDA 0 PERMIT TRANSMITTAL LETTER PERMIT NO. 9-0422-00011/02001 SPDES NO. NY- 0269271

Enclosed is your permit which was issued in accordance with applicable provisions of the · EnvironmE:lntal Conservation Law. The permit is valid for only that project. activity or operation expressly authorized. ff modifications are desired after permit issuance, you must submit the proposed revisions and receive written approval from the Permit Administrator prior to initiating any change.· If the Department determines that the modification represents a material change in the scope of the authorized project, activity, operation or permit conditions, you wlll be required to submit a new application for permit.

PLEASE REVIEW ALL PERMIT CONDITIONS CAREFULLY, INCLUDING ANY MONITORING REQUIREMENTS AND/OR COMPLIANCE SCHEDULE THAT MAY BE REQUIRED. IN PARTICULAR, IDENTIFY YOUR INITIAL RESPONSIBILITIES UNDER THIS PERMIT IN ORDER TO ASSURE TIMELY ACTION AND AVOID LATE REPORTING IF REQUIRED. SINCE FAILURE TO COMPLY PRECISELY WITH PERMIT CONDITIONS MAY BE TREATED AS A VIOLATION OF THE ENVIRONMENTAL CONSERVATION LAW, YOU ARE REQUESTED TO PROVIDE A COPY OF THE PERMIT TO THE PROJECT CONTRACTOR, FACILITY OPERATOR, AND OTHER PERSONS DIRECTl.. Y RESPONSIBLE FOR PERMIT IMPLEMENTATION (IF ANY).

The Department maintains authority regarding the terms of this permit in accordance with 6 NYCRR Part 750. This regulation may be accessed from the internet at the Department's website, htto://www.dec.state.ny.us/ w e b sjte/r e gs/750.htm for HTML format or ht!p:l(Www.dec.state.ny.uslwebsite/dow/part750.pdffora two-sided format suitable for binding and copying. If you do not have website access, you may obtain a paper copy of the regulation at 270 Michigan Avenue, Buffalo, New York 14203, telephone number 716-851-7165.

If you have any questions regarding the administrative processing of this permit or request for modification, please contact this office at the above address. Technical questions relating to the specific conditions should be directed to Mr. James Vogel of our Division of Water at (716) 851-7070.

Respectfully, Steven J . Doleski Regional Permit Administrator DEB:vm

Enclosure

cc: Mr. Gerard Palumbo, Region 9 Division of Water; Attn: Mr. James Vogel Permit Coordinator, Bureau of Water Permits, NYSDEC, Albany USEPA Region II Mr. Eric Wohlers, Cattaraugus County Health Departme!'l~ Erie County Department of Environment and Planning Li .S. Depa11ment or Energy - West.Valley Demonstration Project .. NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION State Pollutant Di.scharge Elimination System (SPDES) DISCHARGE PERMIT Special Conditions ...... Tnduslrial Code: 9511 SPOES Number: '.'IY- 02&'>271 Dischilrge Class (CL): 01 DEC Number: ~422-00011/02001 Toxic Class (TX): T Effective Date (EDP): 11/0i/OS Major Orailiage Dnsin: 01 Expiratio.o Date (.faDP): 10131110,· Sub Drainage 1:1... , in: 04 Moditication Dates: WateT Index !\umber: E-23-33-2-1 Compact Alea: lJC

Tbis SPDES permiL is hsucd in compliance with Title 8 of Article 17 of the En\'imnmental Coru;ervution Law of New York. State and ill compliMce with the Clean Water Act, as aweoded, (33U.S.C.§1251 ct.s«J.Xhereimifter referred tll as "rhe Act").

PER!\.111'1'££ NAl\fF. AND ADDRESS

Name: l'icw York Sta te Eoergy Resear ch mod Development AUenlion: C. L. ~rwitz, rrogram Manager Authority Street: I 0282 Rod< Spring Road Cily: We•t Valley State: f\Y Zip Code: t 4171 is authcnizcd tn di$cb.arge fi·om the facilily described below:

l:<'ACJLl'J'Y KAME ANO ADDRESS

Name: )l\'S 1..icensecl Di8{J'.>3•l Area Locatiou (C,T,V): A¥hford ('f) County: Cattaraugu~ l'aci!ity Addrc.•-= 10282 Rock Spri11g Ro•d City. We.

WQZ - ErdlJl.lln Brook. Cl.us J); W OS - ~y Fre~hwattr We-ti.and t.o Franks C~k. Class<:: W03 & WIM - Tri b. ( unml.m•d) to Fronks Creek, CLm C; W06 - Trib. (unnamed) to Erdman Drook., Cla.s$ D i.u accordauce with: effiucnt limitations; Dlonitori.ug nod ro::porting requirements; otbet provisions nod cooditions •ct forth thi• permit; aud 6 NYCR.R Part 750-l .2(a) and 750-2.

DISCHARGE MONfl'ORING REPORT (DMR) MAD..IN'C ADl>ltESS

Mailing Name: NYS 1.icenscd Disposlll Area Street: 10282 Rock Spring Road City: West Valley State: NY 7,ip Code: 14171 Responsible Official or Agent: raul L. Piciulo, Ph.l>., Director Phone: (716) 942-4378

"!his permit and tbc authorization to discharge .ball expire on niidnig)it of the expiratioD date shuwn above and the pemrittee shall not discharge a lier thccxpir:rtiondate Wlless this pcanil ""-" b.:cn renewed, or eA; eoded pursuant co law. To he nuthnrized to ~e beyotld the ci the c>

DISTRTBllT!ON; Penn.it CuU'Cdinat0r, Rureau ofWater Pennits, Albany ''"'"' ''"""'"''""" Ste\'en J. Dole:W U.S. J;lpA Region JI Eric Wohlers, Cattaraugus Couuty Health Uepartmem AlWRlis: Erie Co11.01y Depor1n1cnt ofEnvironment and Plllllrlir.g 270 Michigan /\ve. U.S. DOB · WVDP ,~ fluffillo, NY 14203-2:>!>!> I S>t"'k l)c . t»c~: 9 ! :1.d' I OS' Ii , ~(1. , ~ SPDES PERMIT NUMBER NY 02692 71 9-0422-00011 /02001 Part I, Page 2 of l 0

.PERMIT LJMTTS, LEVELS AND MONITORING DEFINITIONS ... ~...... , Q(;TFAU. WASTEWATER TVPB RECEIVING WATER EFFECTIVE f!XPJRlNG

Thi• cell de.scribes the iype of wustewnter outhoritcd This coll lists classified waters ·111e dale this ~go The date this page is fur discharge. Example.< include pl'\lC.,.. or $1l<)IW)I of the staic lo which the listed starts in efTect (e.g. no longer in effect. wnstev.·1:1.tcr> sfonn \Vater, non·contact ooolinll \Val:er. outfall dischar2e.. EDPorEDPM'I 'e.i. ExDI')

PARAMETllR MINEvtL::vr MAXIMUM UNITS SAMPU! PRl!Q. SAMPJ •.f! TYPE

e.g. pH, TRC, The minimum level that mu.st be The mrucimum level th.at i11ay not SU, ·p, remperaru~. D. O . maintained at all instant.> in time. be exceeded at any in~tant in time. mg/I, etc.

PARA- EFFLUEIIT LIMIT Pl

U ntit !}'()<$ aro defined be>low in For the: purposes ofcomp liance 1)pe I ot This con 6xamples Uanl>les Note 1. The effluent Umit is ass"6QllCllt, lh• analytiesl nlcihod 'l)'pe II include units Include Daily, include de\·cl0p"1 basod on the tnore speci1ied in the permit shall be used Action Levels of flCt\\', pH, l/week, grab, 24 strlnsent of iecbnology-ba>ed tu monitor the amount ofthe pollutant are JllllSlit weekly, hour >tKDdords, required under the Cleflll. in fbe outlllll to this kwl, provided monitoring Temper.cure, 21monlh, compo.sik Wat.er Act, or New York State water that the laboratory anal)'llt has rcquircmrnt'S, conocntrstlnn. monthly, and 3 grob quality ntrol proecdtues beJo\v in Note include µgil, and ywly. cullottcd nssuroptions and rule~. The'° in the relevant merhod. MoniL<>ring 2, that trigger lbsld., etc. overa6 ali~umpti ons include receiving t1;atcr results thlU 111• lower th3.ll thi• level a<)diliumtl hour hardness, pH and temperature; rate<; mu~t I>< rtp<>rt.ed, but shall nor be monitorios period. of thi• •nd other di•charges to die used to

Note ! ; DAILY DISCHARG\;.: The d i ~ofapollu<:>nt ~ during • cakndardayor:iny2ur period that re9-i)· ~tho col<:ndor 11;,y for the purpose$ of ,..~ling. For poihnauts expressed in unit< ofn.,..s, the 'daily discharge' is cakulotod as tbc total 1na.s.< of the polllllllnt di.«harged O-'-~r the day. For fW'll1U1:lnts \"'·ith linaihlliv~ expn::~~oo in QLh.c.r units ofmca!:l!rctnent. the 'daily dischf:frg<" ~ is e&JculutD() a:1 lhe a\•c.ragc mcasurancnt ofthe pollotant o-.:T the d•y.

DAI!,Y MAX.: The highest allowable daily discharge. DAU..Y MIN.: The lowest allowable cb.ily discharge.

DAl!,Y AVG or lO DAY ARITl:IMilTIC MEAN (30 d•y ovcrowi:).: The highest allowable average of dQi)y di•ol11u~cs over• cit!end:u month, colculated os t~e $um or oacb of the daily discharge• mea

7 DAY ARJTHll,U:.TIC ME.AN (7 day average): The high.. t all11wable ovenige ord•ily clischatges over a colendar week.

JO DAY OEOMBTRIC MEAN: The highest allowable geombtric melln of daily discharges over• calendar month, calcu lated as the lllltilog of: the sum of the Iv~ vf c•ch of the daily discharges m.-sured during a ~lendar month divided by the number of daily discharaes measure

7 DAY GEOMl!TRIC MF.Al\: The highest llllomblc geometric mean of dJfl ydischarges m-er a atlcodm week.

RAN<'.e: The minimum and maximum irunntaoeons meawremeo., for the ICllOTling period must remain between me two values shown.

Note 2: AC'rlON LBVF,LS: Rootinc Action l,cvcl monitoring results, ifn<>t provided tor on the Disclun-gc Monirorin11 Report (DMR) form, shall be appended to the DMR for the period during which tbe 5a'"J>ling Wilt! conducted. Ifthe additi"'ial monitoring requirem"'1t is triggered as not~ bdow, tho permittee s,holl un•. Jf lcv Je.,.eJ i:ixceeded for four of six consecutive s

FINAL PERMIT LIMITS, LEVELS AND MONITORlNG .. • ••.'fl'Cld C.:~l'Jld! I'='• Table A· Outfnll• I OUTFALL N<>. WASTEWATER TYPE Rl:!CRtVJNG WATER EFFECTIVE EXl'IRING

Wiii StoJrrJ\V~tcr discharge Trib. (winamed) ro Erdman Brnol<: (r>) 1!1)1' F.:DP +5 yrs. (t<> S20 of NY 000 0973)

WQ2 Stormwota discharge Erdman Drook, Class D EOP F.DP + s ·yrs.

WOJ StOmJ\Vater discharge Trib. (unnamed) to Franks Creek, Class C EDP EDJ) + 5 )-i·s.

W"04 Slonnwarer d ~ Tril>. (UllDllDlCd) tn Fnmlc; Creek, Oas... C IIDP EDP +S YJS.

WO~ Stoonwatcr discharge l\'Y P~warer Wetland to Franh Creek. C EDP EDP+5 yrs.

W06 Srormv.'!lter discharge Trib. (Ullnamed) to Erdman Brook, Class D EDP EDP .,. 5 yrs. (I<> S20 ofNYOOO 0973)

Table B .. Stermwater ~ameljpf s::1rametert ;,nd fregueng

Table B - Stormwater sampling parameters and frequen!;y

S\\' Group No. SW Monitoring paramelen ad compliance Jim.its • Rota.tlooAl Monllorlng Sequence Ontfllll

Group I WO J, pH • •. The perrnlttee Shall conduc:t semi· 1 W02, pH from on-site rainfall sampto • , annual (2 times per year) monitoring W03, Oil & Gn:JL...: ... on the stonnwater outfaas within eae group. Wh&n there is only one outfan W04, Biological Oxygeu Demand - S days (BOV,), in 1he grovp, semi-annual sampling WOS, aud Chemical Oxygen Demand, shall condueled on that outtall W06 Tola( Suspeoded Sulids, Nitrogen, Total. (as N), and The permittee may chose W01 as th• Ph<>&phorus, Total. representallve sampling outfall for Group 1. The permlttee shall attempt to select one storm event during the period from January to June and another storm event from July to December. The stormwater reports shat! be append ed to the June and December OMR end sempling data repor1ed on the June and December DMR.

Nol!!!: •) - pIJ da1a shall be reported rrom repreeentitive Oulfall from Group I aod on-site rainfa.11 event, and •2 - Compliance limit for Oil & Grease .>ball oot exe«:d 15 m;;/l. SPDES PERMIT NUMBER NY 0269271 9-0422-00011/02001 Part I, Page 4 of I 0

Speclal Requirement for Stormwater Outfalls:

1. The permittee shall conductsemi-annual (2 limes per year) monitoring on the stormwater outfalls. The permittee shall attempt to select one storm event du ling the period from January to June and another storm event from July to December.

2. For each storm event, the permittee shall conduct:

(I) Flow monitoring: The permittee shall collect samples from a storm event meeting the following criteria:

a. Greater than 0.1 inches; b. At least 72 hours from the previously measurable ( > 0.1 inches rainfall) storm event; and c. Wherefeasible, thevarianceinthedurationoftheeventandthetotal rainfalloftheeventshould not exceed 50 percent from the average or median rainfall event in that area.

Samples taken during storm events that donot meettheabovecriteria are acceptable. but must be acoompanied by an explanation.

The ·permitte& shall obtain the following information for each storm event sampled:

a. Date of storm event; ti. Duration of storm event (in minutes); c. Total rainfall during the storm event (in inches); d. Numberof hours between the storm event sampled and the end of the previous measurable(> 0.1 inch rainfall) storm event; e. Total flow from the rain event (in .gallons); max. flow rate during the storm event; and f. A description of the method of flow measurement.

(ii) Sampling:

Minimum sampling parameters at stormwater outfalls are listed in Table B.

For pH, and oil & grease, grab samples taken during the first 30 minutes (or as soon thereafter as practicable) of the discharge must be used.

For all other sampling parameters, both a grab sample collected during the first30 minutes (or as soon thereafter as practicable) of the discharge and a flow-weighted composite shall be taken for the entire event or for the first three hours of the event.

3. Reporting:

The pe1-mittee shall summarize, analyze and report the stormwater mo11itoring data to the address listed in the Recording, Reporting and additional Monitoring Requirement page of this pennit. The stormwater reports will be due no later than the 28" day of ttie month following the end of each reporting period with the regular DMR.

4. Prohibition of non-storm water discharges:

Discharges of material other than storm water must be in compliance with the provisions contained in the non storm water portions of this permit. However, the following non-storm water discharges may be authorized by this permit provided that the non-storm water component of the discharge is in compliance with the practices and provisions developed in the BMP Plans as required by this permit: discharges from fire fighting activities; fire hydrant flushing; potable water sources including waterline flushing; irrigation drainage; lawn watering; routine external building washdown which does not use detergents or other compounds; pavement washwaters where spills or leaks of toxic or hazardous materials have not occurred (unless an spilled material has tieen removed) and where detergents are not used; air-conditioning condensate: spring: uncontaminated ground water seepage; and foundation or footing drains where flows are not contaminated with process materials such as solvents.

5. Storm water pollution prevention (SWPP) plans:

Stormwater water pollution prevention plans shall be.prepared in accordance with good engineering practices and in SPDES PERMIT NUMBER NY 0269271 9-0422-000 l l /02001 Part I, Page 5 of l 0

accordance with the factors outlined in 40 CFR 125.3(d)(2) or (3) as appropriate and can be combined into one document with the Best Management Practices Plan. SW PPP related to the storm water discharges from construction activity should follow requirements outlined in the "General Permit for Stormwater Discharges from Construction Activity - Permit No. GP-02-01."

The SWPP plans shall identify potential sources of pollution which may reasonably be expected to affect the quality of storm water discharges associated with industrial activity from the facility. In addition, the plan shall describe and ensure the implementation of practices which are to be used to reduce the pollutants in storm water discharges associated with industrial activity at the facility and to assure compliance with the terms and conditions of this permit.

6. Radioactive materials:

This SPDES permit does not authorize the discharge of radioactive materials. SPDES PERMIT NUMBER NY 0269271 9-0422-00011102001 Part I, Page 6 of 10

MONITORiNG LOCATIONS The permittee shall rake samples and measurements, to cornply with the monitoring requirements specified in this pemrit, at the Jocation(s) specified below: Nute: Cross-retercncc SPDES outfall numbers to other n11tations: WOl = WNSTMOt; W02 = WNSTM02; W03 = WNS'ni03; W04 = WNST.\i04; WOS = WNSTMOS; and W06 = WNSTM06

.. ..,;...... _.. ..,,_ ....,.,.._,.... -'ITACHWIMI' J--t ~~ -..~~~

DISCHARGE NOTIFICATION REQUIREMENTS

(a) Except as provided in ( c ), (f) and (g) of these Discharge Notification Ad requiremenlli, the permittee shall install and maintain identification signs at all outfalls to surfaco waters listed in this permit. Such signs shall he installed before ini tiation of any discharge.

(h) Subsequent modifications to or renewal of thi~ permit does not reset or tevise the deadline set forth in (a) above, unless a new deadline is set explicitly by such pennit modification or renewal.

( c) 1be Discharge Notilfoation Requirements described herein do not apply to outfalls from which lhc discharge is composed exclusively of storm water, ur digcharges to ground water.

(d) The sign(s) shall be conspicuous, legible and in as close proximity to the point of discharge as ii; reasonably possi\lle while ensuring lhc maximum visibility from the surlilce water and shore. The signs shall be installed in .such a manner to pose minimal hazanl to navigation, bathing or other water related activities. If 1he public has access to the water from 1he land in the vicinity ofthe outfall, an identical sign shall be posted to be vii;ible from th.e direction approaching the surfac"' water.

N.Y.S. PERMITTED DISCHARGE POINT

SPDES PERMrr No.; NY___ _

OUTFALL No.;_ _

For information about this permitted discilarge contact: Permitlee Name: ______

Permlltee Contact: ------Permittee Phone: ( ) - ti## - ####

OR:

NYSDEC Division of Water Regional Office Address :

NYSDEC Division of Water Regional Phon e: ( ) - ### -##11# .

The signs shall hav<: minimum dimensions of eighteen inches by lwcnty four inches (18" i< 24") and shall have whit.e letters on a green background and contain the following information: e) For each discharge roquired to have a sign in accordance \vith a), the pcrmilteeshal!, l)oncurrent with the installation of the sign, provide a repository of copies of the Discharge Monitoring RcporlS (DMRs), as required by the RECORDING, REl'ORTL"IG Al'iD AnnmoNAL:\fONITORING REQUlllE'.\fENTS page ofthis permit. This repository shall be open to the public, at a minimum, during normal daytime business hours. The repository may be at the bui;in.,,ss office repository of the permi ttee or at an oIT-prcmises location of it~ choice (such location shall be the village, lown, city or county clerk's office, the local library •)r other localion as apµi:oved by the DcpartmCTll ). In accordance with the RRCORDTNG, REPORTING Al\}) ADDITIO:NAL '.\10NITORING RF. QUTRF.MRNTS page of yuur permit, each DMR shall be maintained on record tor a poriod of three years. SPDES PERMlT NUMBER NY 0269271 9-0422-0001 1/02001 Part I, Page 8 of I 0

(continued)

(J) If, upon Novemher I, 1997, the permittee has installed signs that include the information required by l 7-08l5- a(2)(a) of the ECL, but do not meet the specifications listed above, the pennittee may continue to use the existing signs for a period of up to Jive years, alter which the signs shall comply with the specifications listed above.

(g) All requirements of the Discharge Notification Act, incl uding public repository requirements, arc wai ved for any outfall meeting any of the folio"mg circumstnnces, provided Department notitication is made in accordance with (h):

(i) such sign would be inconsistent with any other state or federal statute;

(ii) the Discharge Notification Requirements contained herein would require that such sign could only be located in an area that is damaged by ice or flooding due to a one-year storm or storms of less scv~'Tily;

(iii) instances in which the outfall t.o the receiving water is located on private or government property which is restricted to the public through fencing, paD'olling, or other control mechanisms. Property which is posted only, without additionttl control mechanisms, does not qualify for this provision;

(iv) instances where the outfall pipe or channel discharges to another outfall pipe or channt:I, before discharge to a rccei ving water; or

( v) in.stances in which the di scharge from the outfall is located in the receiving water, two-hundred or more feet from the shoreline of the receiving water.

(h) If the pennittee believes that any outfall which discharges wastewater from the permitted facility meets any of the waiver ~-rit.eria listed in (g) above, notification (form enclosed) must be made to the Department's Bureau of Water Permits, Central Office, ofs uch fact, and, provided there is no objection by the Department, a sign and DMR rerository for the involved outfall(s) are not required. Thi.~ notitication must include the facility's name, address, telephone nwnbcr, contact, permit number, outfall nwnber(s), and reason why such oulfall(s) is waived from the requirements of discharge notification. The Depar1ment may evaluo'te the applicability of a wai,,cr al any time, und take appropriate measures to assure that the ECL and associated regulations are complied with.

(i) The pennittee shall periodically inspect the outfall identification sigl'ls in order to ensure tbat they arc maintained, are 5ti1l visible and contain information that is w rrent and factually correct. SPDES PERMIT NUMBER NY 0269271 9-0422-00011/02001 Part J, Page 9 of I 0

SCHEDULE OF COMPLIANCE a) The pemriuee shall comply with the following schedule.

Action Outfall Code Number( s) Comnliance Action Due Date

St1>rmwater .l'oll11do11 Preventl«>n (SWP.l:'l Plans :

Submit SWPl' Plans according to the outlines iD this permit. EDP~6mos.

The above compliance actions are one time requirements unless othcrw.ise noted. The permlttee shall comply wlCb cbe abo\'e complian"" actions to the Departmait's satisfacti1>11 once. When this pernllt is administratl\'ely renewed by NYSDEC teller entitled "S1'1lESNOTICEIRENE\VAL APPLICATION/PERMIT", tile permilteeis not required lo reput lhesobmissioo. The aoove due daWs arc independent from the efCccdve date «>fthe permit staled in the lett•r of "SPDES NOTICE/RENEWAi. APl'LICATIO:-l/PERl\UT." b) The pcTmittco •hall gubmit a written notice ofcompliance or non-compliance with each ofthe above schedule dates no lacer than l 4 days following each elapsed date, un!esi; conditions require more immediate notice as prc•cn"bcd in 6 .'.'IYCRRPart 750-1.2(a) and 7 50-2. All s11chcomplian~e ornon-coropliancenotification shall be sentto the locatio11s listed under the section ofthis permit entitlcdREUJRDIKG, REPORTJNG Al\Tl ADnJTIONALMONITORING REQUIRil.\1E.'lTS. Each notice ofnon-compl.iance shall include the following information: 1. A short description ofthe non-comp!Wicc; 2. A description ofa11y actions taken or propo&ed by the permillee ro comply with the elapsed schedule requirements without further delay and lo limit en•iromru:ntal impact am>ciatt:d with the rum-~ornpliaocc; 3. A description or any factors which tend to explain or mitigate the non~ornpliance; and · 4. An c•timate of the date tbe pennittee will comply with rhe elapsed schedule requirement and an assessment of the probability rhat the permittee will meet the ne>tt ~chcdnlcd rcqnin:mcnt on time. c) The pamiltce shall •nbmit copies ofany docnm£nr required by the above schedule ofcompliance to NYSDEC Regional Water Engioocr ar the location li$oed u11der the sectio11 of Ibis _permit ~ntitled lillCONDlNG, REPORTING A!'IJ AlJDITiONAL MONITORING REQUIRilMI!N"fS and I«> fllellurean of Water Permits, 625 Br<1athvay, Albaoy, :11.Y. 12233-3565, unless orherwise speci(ir.d in this permit er in writing by the D

RECORDING, REPORTING AND ADDITIONAL MONITORING REQUIREMENTS a) The permittee shall also refer to 6 NYCRR Part 750·1.2(a) and 750-2 for additional information concerning monitoring and reportirtg requirements and conditions. · b) The monitoring information required by this permit shall be summarized, signed and retained for a period of three years from the date of the sampling for subsequent inspection by the Department or its designated agent. Also, monitoring infonnation required by this permit shall be summarized and reported by submitting;

0 (if box is checked) completed and signed Discharge Monitoring Report (DMRi forms for each_6_month reporting period to the locations specified below. Blank forms are available at the Department's Albany office listed below. The first reporting period begins on the effective date of this permit and the reports will be due no later than the 281h day of the month following the end of each reporting period.

D (if box is checked) an annual report to the Regional Water Engineer al the address specified below. The annual report is due by February 1 and must summarize information for January to December of the previous year in a format acceptable to the Department.

D (if box is checked) a monthly "Wastewater Facility Operation Report... " (form 92-15-7) to the: Regional Water Engineer and/or D County Health Department or Environmental Control Agency D specified below

Send the origlnal (top sheet) of each DMR page to: Send the first~ (s&e0nd sheet) of each DMR page to: Department of Environmental Conservation Department of Environmental Consenration Regional Water Engineer, Region Division of Water 9 270 Michigan Avenue Bureau of Water Compliance Programs Buffalo, 14203-2999 625 Broadway NY Albany, New York 12233-3506 Phone: 716.a51-7070 Phone: (518) 402-8177

Send an additional~of each DMR page to:

c) Noncompliance with the provisions of this permit shall be reported to the Department as prescribed in 6 NYCRlt Part 750- l.2(a) and 7.50-2. d) Monitoring must be conducted according to test procedures approved under 40 CFR Part 136, unless other test procedures have been specified in this permit. e) Ifthe permillee monitors any pollutant more frequenUy than required by the permit, usi11g test procedures approved under 40 CFR Part 136 or as specified in this permit, the results of this monitoring shall be included in the calculations arid recording of the data on the Discharge Monitoring Reports. f) Calculation for all limitations which require averaging of measurements shall utiliZe an arithmetic mean unl!!SS otherwise specified in this pe1mit. g) Unless otherwise specified, all information recorded on the Discharge Monitoring Report shall be based upon measurements and sampling carried out during the most recently completed reporting period. h) Any laboratory test or sample analysis required by this permit for which the State Commissioner of Health issues certificates of approval pursuant to section five hundred two of the Public Health Law shall be conducted by a !aboratory whicll t;as been issued a certificate of approval. Inquiries regarding laboraiory certification should be sent to the Environmenlal L~hm·atory Accreditation Program. New York State Health Department Center tor Laboratories and Research. Division of Environmental Sciences, The Nelson A. Rockefeller Empire State Plaza, Albany, New York 12201. CND:,.!.99C'.Qawnkad FUo'{20"50103) 'Fni:t$. mW.•Jx1 SPDF,S P.F..Rl\.DTFACT SHEET: Wastewater Data, Re<:ei\ing Water Datii, and, Ponnit Limit Derivation. Dace 01/03/()5

~las!pa:ei ol(t

"°'Q .t:vgir1ttr

(l) GeneYal Permittee Data;

PmMNunlbu Pcrtri1:Dx~XO: Y.a.cilhy Xarnc Location (C, T, V) Coumy Industrial Code Major/Sub &si n

- ~y U26 9271 NYS Ene:J:,~Rest'aroh and f)c;:vclq_"ncnt.~uthorityNYS Li~ D~posalA~a Ashford C1.lfarau.gu..s 79;1 (Air. Wa1'r, Solid Wa.-&. 01.\14

MOW>~ nt)

(2) SummMry of Final Outfall Flow Rate(s) and ReceMog Water Data'

Ou1l•ll l atOrmatioa R.ettivin.x 'W·aM leformaOoa

,....,,rUK« 1VQ F.11gfnet:t Critic;ii eu - Lttdtuclc 1~1girudc Flow Ratt (MCO) hy - l o. t);lutii.m/ Oulf.11.114~ Ma.'dmumo1 Wuttr fndcx 7Ql0 JIJQIO pH Tcnip Hardntss

.... . ' " Avi::T&J;C t)c~ll(fl Nnn" Class NUmbet (MCll>) (MGD) Mixing (SU) r,.> (ing,1) -·- I) yAJ'iubl~ WOJ 42-26·.~5 78·39·01 Vclriable Trib. (unnamed) to Erdn>•n Oru<>k (0) l\-Z3-.13·2· l

W02 42-27.01 7R-39-0t variable variable Erdma.nBmo k (Il) D ---\\.1>3 42-16·56 78 JS-56 vuriJitble variable Trib. (ln11t111.,d)lo r-

wos 42-26-.S2 3g ,,lfria.ble vari1hlc Trjb, (uru>amed) '°IZrdmltn ~nu >k [)

Nole: * t>reviuu~( >urfoll ff dcsigna.tiDnjs illdicared ii\ the fulluwing pnri:nthct.a't:

WOI rso.2 1 j; WOZLS<.l·2? f; WO) (S0-291: W04fS0.24 J; wos l S0 - 25 J; ••d W06[SO-ll l.

...... ~ ......

C:'.Dowaw.d Filo.'{2005 0103) Ml' I • G::J• f [2J I Date J 01/03/05 :J

(3) Individual Outfall Data Summaries and Permit Limit Development; Outran WOS (i.e. previously as Outfall S0- 25 in the 912712000 application} I --Souroc(s) of Wosl<\l>~tu ~tomYWS~ruoofffirun Area OS(i .e. pn:viuw: •rca 1.i) nf'tht; SDA.. ,_[h:ls____ tini; \IJ~tc"" ·atrr'l'rtacmcnt .FacUlt.ie.s :\ i,,nc

Eri\ Pun:eCa tegory &. l'TClducllonRa te NA

:r.fflu~ntPar•meter (Units) Exi1dic.i;: Emunr Quality T"hnoklgy Ha~ fi.fllue11.1Ltn11t \\'atcr Qu.ality Rated EIDUt".lltLl111lt P..:rmit Bash (T .,.. (conccnaaU011 units • 111g/I, Cnnccntr\l1i-0n(From stonn eveul uf 9i20/I ?95} • PQL A\VQC Ealuml ug:l .llf' ni:;.'I~mas:;. unili; - lh;,/(l WQ) or ;t'd)

Grab san\Ple u\ren I R1lw weighted Comri5iW C(ll\O. mass Typt:: cone. Mash cone. ronc. m~ s:.: Typo <30min.

\Vtrr lESTD'{G ~A JUCd•11nt~I Yl!Sf:-iO ~-·- OowRn=.mill - }'A ·"''"ft'&~

pll (:PJ) 7.11 ft)llllitlf 1'>og<

Oil&G~ rar;l <5.0 -···- IS --·· -·uon .s, ~ t •:2.0 ... 2.0 )tmdtor ll'>I>. ms/I •:~ .<> 14.Y MonJtt'O'

SolW. Total Su.tpc1tded 10 rnw1 61Q1l!l M(M1itor

Ni1r0gm.r. ..; 1.02 mg.II '- 1.• SllQW1 M

-J'hn'pol"'"'i&S,T. O.O

Ahlt'lli"WlL l . ...~ t.1.2~ 0.245~.'l

Antimoo:.--. T. <(l.(l6n1.,11ll

'! .neoic, $0.ltlbJe < 0.UOJcn5; l <0.0001313"1 -I'. < O.OJ • .,, < o.os"'1'I -·-I' 0.U14 O!Soi 0.01'"'!>1 l.':ttlrni1,1~--TR <0.00lt~ •:Q.002~1 1, Cali.:j1t1rT. J4.4~ 1 l.J.1 mit•'I

Cb11>1ni.u1n,rl( <0 .0021ll;ll <0.002 mg:1

Nmc: • Uvri1111'P'ffl'lrit.proufld oi; scoge. pern\incc aotonincd an up~d :'WUt:!-1~rmi lniiplkm fi

( S11 e.s .- 1 3) ln•lb:jd unl Outfa!J D ata mma ri on d Perll'i t L imit Development: Outfall W05 (i.e. previously as Outfall S0-25 in the 9127/2000 application)

E.ffl'Jta t P1nund~r(Unit.:) F.:ritling Ef6a.t:nt Quft.lity T eclluologr Based E.IOutnl Lim.it \Yater Qu_alily Du cd Effiul-ot J ..imlt Pitrmlt Da_lii• {coctcent1ii1tionutllCl • mgi1 {Tor 1 Coocenttalion (Frum ~lurmevent nf 9.'2J)f1995) AWQC Btlh1cnt ugt1 or ngll; 1uas.sllnits • Jbs/d PQL WQ) OJ•gld)

Or•h 11amplc ta~ Flat\' ..veigbted C01upo11itc cone. moss Type cone. Httds c1>nc. Cl)I\(;, I .,.)'JIC <.30 ml• . """"'

Cur~r,Tl~ < O.Ol ruGIJ <. o.o•mr:J

<:r1r1:.;r, :S•Jhlbh: < 0.01 ru~1

Chn'llll1urn(l 6), Tlf,, ...::o.Otru~·l ·~O.Ol11'la:'I

Jrou.. T. 0.19 q;·l 0.1$1m@/I

l.eod.'JR < O..OOlcns:l

"",..,...... l. 1.71 ••ll• 1.65~1

~T. 0.01 mi,1 D.CIO:'111,&1

M~ ·T,. <0.0002~ < O..ODln Titg"1 - l\;ckr-1,TR .,, 0.()4 1""1 -:0.04~·1

l'!'ll&$$i111ri, ·r. •: Jm,11 •: 1 n1r :I

S:lc11iun1,·1 X < 0.00'.'i1"gt1 < 0.003 1r1s11

Silver,T. < n.nn~mx;1 c:0.003 JU&•1

Sodi11m,T <,;,JS ma.·1 ~IJnjf,'I

Tllalli 1ut1,· rl{ <0.00> OQ&'l ·~U.00 3 inafl

Ti(uil1Ult. 7 . < D.MD 1"11'11 < 0..0-SOrui; ·l

V<111du>,.7R < 0.01 .,,., ~0.01rug.'J

Zio<..Tit 0.191 o-..i 03 B qi-1

C.\IOtik.iR .r.'0.W4 o)!.i ~O.QCM~ -·------flt'fl;>,(11.e < 0.00S nt,gfl <: D.00~~'I 2 · llul:mqnir < U.01 1nWJ <0.01 ~··

-·l~1 C:h n1fl.1ttn <( o.oos cn;.'l .. 0.005 '"&''

Dictlk>rOOiR~111~«h11n11" <0005~ < 0 .003 n'®'I --l,I • Diehfor~tl13.1~ <0.00.'i m~ I < o.oos 1ns:1 ~1'i.>i:SnKMrr FA(:7 lj HF.KT: Permit Nnmber )IY I OU 9271 I ,P•llO EJ of EI I Date I 01/03/05 ·1

(3\ ln d jyjdual Out fa ll D ata S pmm arjes and Perqiit Ljmit De~~clopm ent: 1 Outfall WOS {i.e. previously as Outfall S0-25 in the 9/2712000 application)

Emueat P1uumd.r:'r {Unib>) J:Tilti•g ft.ftlueut Qualtty T r('hnnlogy Ba..1:ed IF.fJlarnt Limit Wa.lcr Qu.»lity 8 u ed 1:t"f1&1ent JAmit Pmnlt Bads (•:.oncenlrotlcm unll'>. mg.l1, (Too· .,ooec:ntr1tllon (fr-om storm event of9i2.U/19~5) PQJ. AWQC EaJut:nL ug:l or 11pfl~mas.; uniU;- Jbii.'d WQ) mgid)

(lr.ab s.Jmplc takcri flow weighced conG. m a!i1> 'f')']l< Cl>JIC. n.. 1. cunc. crmc. malls Type

l ,2 - Dicbloropropaoc ..; 0.01 mg,1 -:0.01 rn;c.1 >-·

[1byl Benzeoc < O.OOScn~·1 o:.U.Olll 1'1"$11 >--

Mi;lbyl

T ri.:11ltirtin uun1 ru11:d1:.1.11~... 0.001 IO(Ql <().005 U'lll·1

TClne~oclb)icoc < OJ>Olr~1 <0-002~

OJ)()$ -x,.Jene.~1. < m:p1 <

0i!i(2·eltl~·lhcxyl)pllt~U.te •: O.Ol int>'l

.: 0.(>l n1;:/I -3.3 - Dicll'°10-bc112idi1>e '· CJ.Ol ""t'I 4 - UuGttt'I•~ -: n.Mw,Jl <.0.06~1

Hc.'t11chlorobeaze.nc '0.0 1 m;ll ·~U.OJmg/I -N:~phl·11;,.l~.i: " 0.01 l1a~ .::n .01 l'llf''l <0.0!~

ACpba - 8HC 0,()(1(101' "'~' < o.oooos

Bqi•""" < CIJ>ll0009fl'IJC-1 ,, O.OOOOl..,:I T...... < G.CJ0009.., , <.0.002 rtWl

Q.UiS mW! 0.086 ..,,,.1 --·--Olloride < >.<>1ns:i < 1.0 111gfl Nol required Cyan)de, ;\men.able to tllJoriMdoo o.ss""" J':uoriJr .::n.J mg·1 O.H N(;.'1 --~itr.aw.l\iCJng.eo n.>e2mWI 0.8611Jll1l Sl'DES PERMIT FACT snr.ET: Ptnnlt ~·umberNY I 026 9271 I ~pageEJof EJ I Dllte I 01103105 J

CJ> lpdMsh1aJ (P11tt?ll Dgtp Snmm1ri1·:e and Prrmjt ·imit Development: t I 1 Outfall W05 (i.e. previously as Outfall S0-25 in lhe 9/27/2000 application)

~:tlluen1t'araJ11tter (linits) E:dstlu{: Emurul Quulily Te

con~. mass Type cone. Bui,; oonc. cone. lDaSS Type

l\lbi.te. :'liboy:n < 0.05 lnsl\ .;: 0.05 rng:l

l\oo-Pl1rgeable O~ooicC1rtoo 1.4 nlgll lmyl

S~lid~,8':11kablt < o.J 111(11 <0.L ftl~'l

Sul:li.16 lR.2 m#I l~i"""'

Tottl Dissolved Solida n1~:1 -·--·· 66 mi·1 b4 Tt:npminm: 17 Dci;n:c C -···-·

Tolal f'h(nob •: 0.005 nlgll <-0.00S ms:i ·-· 1·0•<1>1Ory,41oic Hultlks 0.007nlg•1 0.007mgll

AniQ111;::;1,1rf:u;1ll'l1 ~ .;:1),025~ <0.025~·1

fSica1bm13.leAlkali11ily 32.4 nol:Y'I 1J.!\m,.~l

Calbon.atc .<\ll:alioitj ·~Smg/I •:5 "'w°I OH·H>-drox.)'l- A~lillity <5ruclJ ~~1:11 Ch!orior RtNl1ual <:0.1 mgll c:0.1 ruclJ • R~~

~~.'>llll'i~.dit~l\·cJ .;.1m~'l < 1 nlg•l~~

~~~-·--··-~~

~~~c; •r...... t:ntliablelumdiablc doc to a holding tjinc ~cda.tloc. f'trntlt NurnbeY ~·y I OUi 9271 1.p•ge EJ of EJ~~

( 4) Additi1>11al Issues: Wattr Qo•lity Da>Od ElRutnt Um;u (WQDEL&): Nc:w Voit.; Stttc water quality rcgulations(fnrs1.1rfi~ '\\'ati:rs) zir¢: implQTitcntcdby applyjng the Tou>J Mwr.imum Daily [.()ad (I'MDL)procc:$d to watcn>hed,, ctrainagi; basins (lf watemodyscgmmls<1n a po1lutants.pec1fic basis. 1he.ana1y&1s detmnines iflhm:i:li!V ·Dosed Dece Clean Wa!or Act ~113(d)...... - ..----·-- - PMrameter

~~Nno\10( (0 be Allocated (IMDL)~~

~~Numbc:rufSoun:c:I\~~

~~AJJocation to thls Pennil~~

Statbtic~: The MattstiGal n')tth<1ds udJized are cons.i~lenl with TOCS 1.2. l anil the llSEPA, Officenf\Vat<:r, TcchnieaJ SupportDocu1ncntFor \VaterQuaUty·basedToxics Cunbnl, li.tan:h •991, ApPt:ndix E.. Ciem:ralfv ha.<)crl on lo~nttal ;11ualysjs. Jfothc:r data djstt•ib\Uions SlJch .a.s nomwJ urdelbl-fn,1:'nllmllll mi: utiliz.cd it is noted bclnw. Statistical eaJculaCjons v;crenotpert·onned f

~~Mtmitoring daaw cullccted during the f(lllov.'ing Jin1c period v;as u~ to c:\leufare statlstks: Thii> d:.ta w:11s la.ken fimn the fnllm.,ing soun;c(s):~~

Inter11.el \Vast~ Strct.1n :W:o•ltoria~: 40CFR l22.4S(h)(l)alln\»·.1thcpcmnt :.1,1.thoritykl rnonicocand litnitp3famct~'Sat inte.i'tlal locations whcnwntrullingthcmoolelyat the final outfall is ia:np11:cdcal orintt.a.sible. Diluti<1n of a process, wasring point is jw.tified. Mcmitnring ut thi: fulluw1n:.; intemal outfalls l$t neccssal)' for tbQ ~asons spcciticd:

\VEI' Tt.sth1i;:: Ti:sting ls •cquircd, in acconlancc '\\-ith TOGS 1.3.2, for the tOUoy,·ing l-eaJOns.: lndic&tor P11n.mcicrs: In accordance ,,,.ilh 40 CFR J 22.44(c)(2), The permit writer has detenrUoed that efra.:tivc tn:atmcntind/or acccpt:.b1c:pcrfonnsnQC for~itic pmmeters is indicated by une CJ' n'°te 01he:i·paromeLers whkh •re limiu:d and therefore a dcci,ion has bcc11 tlll

~~Sch~duJe of Camplian~..-:~~

~~(5) Summary of Proposed l:'ermlt Changei:~~

~~Compared to the isr.ucd pmnit this~~

• Group I: Change pH compliance limit to "monitor'' at the represenlalivc uutfall and rc"Port pH value from on-site rainfall sample, and - Group 2: Delete Group 2. rerinlt N1unbtl" NY I026 9171 1.p•~" EJ af E1

(6) Explanatory l'iotes: P:ease noce thal some of tllese ll!nns Qre n.:>l a:ppJicabJt: to evc:ry fitct sheet. AL- Acti011 lQ\·cJ caJculatcd tn acoordance \\•ich TOGS L.2.1 (non POT\V~) und TOGS l .3.3 (PO'f\Vi;). Sec the pcnnit for a oompJcte detinitioo. A'\'O l>I' Av - i\\'tr1>:;;e. The arilhmclic mean. A. \'v'QC • -~.lnbiel\t1\':\ter~u:\lityedtel'i.afbrthe teceivini: w.at~. The appJicabJe slwuhll'll, guidunci: v::1.lui: orcstimmd val~ inaooordance \Yith TOGS 1.1.l, TOGS 1.3.1and6NVCMM7011-7115. Basis - The technical ~aJ)'SiS> inlim!llll i.;uiJm.:c, rei;ulatinn 311d:'nr b11\\' U)Klft "';hjclran d'fluent lim(C or monitol'iug requjren>ent ia pruposed. BAT· Bcsl AV>il•blo Tt<'hnology Eoonomic•llY Achiev•ble in •ccoroance with TOGS 1.2.1 (ncm MTWs) and l00$ 1.3.J (l'OTW&), 40 CFR 125, 61\YCRR 754, 1'CL l 7~811 •nd die Clean Wao;r Act. DCT· Best ConventlonaJ Conttol TechnoJ<>gy in 11.voonl11.ncc wilh TOCJS 1.3.4, 40 CµR 12$, 6NYCRR 7.54, tiCL 17-0811 and the Clean Water Act BPJ • Best Prc1fe5•;on>l Judgomcntin accordan<:e with TOGS 1.2.1 (non POTWs)and TOGS 1.3.3 (POTW•), 40 CFR 122 snd 125, 6NYCRR 7S4. I, l!CL 17· 081 I •nd lhe Clean \Vah:r Act. . BrT • flo•l l'raclitable C'.on(.lS 1. t .2 and 6WiCRR 703. Ind· Indicated paltdneter. Sec definition in 11ection (4). Tnlerim- Interim pcnnit pcl'i1mance thi1t mu.st be uchic:vcd while irrqJrn~·cmcnt11 3rc being in1plancnted in order to .ichje1.>e final ptl'nUt perlud WL!Uirm>i:mt... lb$ld or ~id - Pounds per day discharged. Mass .. Mos:. dil:>l.:twr.,;e in units of #/d nr g;'d discb.irgc. l\o1axM~1x - ·1·h¢ m2ucimum "'aluc. MGD· Mi1li<1n gallun¥. pi:r day. mg11 • Dih1.fi<>1t/Mixing • ~:!~f:~t~~~ilut~nn 3v3ilablc in ~ceivjngv.-atcrs. for Jakes, csruarie.s and slowly flowing ri..-etherwisc:. Mooel. Ca1ibn11,ed ...... 1~ qUKlity model applied in accor of thi~ panmete:r and tbc reported disch3fg<; l~cls do not justify l'OUtine fMllik>ver uf i1 tcchnotngy bssod requirement an R(WQ) ;, roll over of a WQDEL Range· Tile dtschar,tt: is limited ma ransc <1f ¢t'{lUQOl vafut.S, <;.J- a pH Jilnit of (6.0·9.Q) SU. RMfif.. Ht>A •s Risk Reduction Eng,ineennt Lebotui>ty trula.bihty ililt.a~i:. T· TechnoJa:;:y b11sc:J eftluent timit orr~uircntcnt. TOGS· Tee1n1i~atand OperationalGuidonceSeries. Inretaal tuidat\ce ta pennlt drWleTS u$Cd tt)-thi; N"\"Sl)8C lli,·ision ofWater to aid in perJnitdtnftini:. Copies of these guidani;e documc:nts ITU')' be obtained fron1 tbc intcrDCl at hnpJlvtww.dcc.su.te.ny.us/websittldo\\1/ll)!,Vindcx.hlm, "!>.~. Microgiams P<• liter. 1000 U$ll =I mg/I. v.-rr. V.-llolei.ffiumL T<1xioity (ttl>ric;:iJ effillent dota. used Li> ()rj.f\ thi: 1JC1111iL · }3}· Secondary tl:eatntenl 1'Ct.)Uircm:mb. in :tccnrdance with TC)GS 1.3.J, 40 Cl:'R 133, 61\YCRR 154. ECL 17.0509 nad the Cle'dll \Yater AcL Thc.oec ~ramctc:rs rcprcscnc scans. Detections \'at;· among the cootPo11t1ds which ure int:ludcJ in th~ ~c3Tl~. The Jjstcd vaJue reptesent the uwciJYUJ.m ddecced level of any t:umpuund in the ~can.

~~Appendix B – Performance Schedule~~

Task 1M 1MR 2M 2MR 3M 3MR 4M 4MR 5M 5MR 6M 6MR 7M 7MR 8M 8MR 9M 9MR 10M 10MR 11M 11MR 12M 12MR Task 3 Jan Feb Feb Mar Mar Apr Apr May May June June July July Aug Aug Sept Sept Oct Oct Nov Nov Dec Dec Jan monthly 31 15 28 15 31 15 30 15 31 15 30 15 31 15 31 15 30 15 31 15 30 15 31 15 Task 1Q Field 1Q Report 2Q Field 2Q Report 3Q Field 3Q Report 4Q Field 4Q Report Task 3 March 30 April 15 June 30 July 15 September 30 October 15 December 31 January 15 Task 4 February 10 Lab + 15 days May 10 Lab + 15 days August 10 Lab + 15 days November 10 Lab + 15 days Task 6 December 15 4QTR Report and March 15 1QTR Report April June 15 2QTR Report July September 15 3QTR Report annual statistical 30 30 October 30 report January 30 Task 1S Period Field 1S Report DMR 2S Period Field 2S Report DMR Task 5 January 1 – May 31 Lab + 15 days July 15 July 1 – November 30 Lab + 15 days January 15 Task 1S Period Field 1S Report 2S Period Field 2S Report Task 2 April 1 – May 30 1S 1S Report Lab + 45 days Oct 1 – Nov 30 2S Report Lab + 45 days Task Five-Yr Nonroutine Monitoring Field 5-Yr Nonroutine Monitoring Report th Task 10 April 1 – May 30 (every 5 year) 5-Yr Nonroutine Report Lab + 45 days Task Annual Statistical Analysis Task 3 January 15 for the prior year Task 4 January 15 for the prior year Task 6 January 30 for the prior year Key: Task 2 = Groundwater Sampling Task 3 = Monthly and Quarterly Groundwater and Leachate Elevation Measurements Task 4 = Surface Water Sampling Task 5 = Stormwater sampling Task 6 = Environmental Radiation Dosimetry Monitoring Task 10 = Five-Year Nonroutine Monitoring Q = Quarter S = Semiannual DMR = Discharge Monitoring Report M = Month MR = Monthly Report

~~This page intentionally left blank.~~

~~Appendix C – Safety, Training, And Handling of Chemicals and Waste~~

~~Safety, Training, and Handling of Chemicals and Waste~~

~~1 Safety~~

(a) While performing any work under this Agreement at the Western New York Nuclear Service Center (Center), the Contractor is responsible for taking all necessary or required measures to protect the safety and health of its workers. In addition to any other penalty that may apply, the Contractor shall be held financially responsible for any work delays resulting from unsafe practices.

(b) The Contractor shall identify a safety and health representative for each task who is responsible for overseeing and managing site safety and health procedures. The safety and health representative must be qualified, available, and authorized to work with the NYSERDA Project Manager and the Safety Staff to ensure that hazards are identified and controlled; and that site safety and health procedures are effectively implemented and, as necessary, modified to reflect any change in site conditions.

(c) The Contractor and subcontractors shall comply with all applicable federal and state regulations governing occupational safety and health. The Contractor and subcontractors must have their own safety and health programs. The Contractor must incorporate task or job hazard analyses and written safety and health controls into plans, procedures, or other work planning documentation for each task or operation implemented under this Agreement. The Contractor- designated safety and health representative must work closely with the NYSERDA Project Manager and safety staff to ensure that the contractor’s safety and health practices being employed at the Center are consistent with NYSERDA’s practices, procedures, and plans.

~~C1 of 2~~

~~2 Training~~

In addition to the requirements in Section 1, employees of the Contractor and subcontractors who will be working at the Center under this Agreement must maintain current Hazardous Waste Operations and Emergency Response (HAZWOPER) training in accordance Occupational Safety and Health Administration (OSHA) 29 CFR 1910.120 and, where warranted, training that is in compliance with Department of Transportation regulations, Title 49, Part 172, Subpart H - Training for packaging and transportation of hazardous materials. In addition, the Contractor and subcontractors must have completed any additional training required by OSHA standards for specific tasks.

NYSERDA will provide additional site-specific training required as described in the Statement of Work. All training requirements must be fulfilled prior to the initiation of work. The Contractor must work closely with the NYSERDA Project Manager and safety staff to ensure that training requirements are clearly identified and completed.

~~3 Handling of Chemicals and Waste~~

a) The Contractor shall provide the NYSERDA Project Manager with a copy of current SDS for all chemicals that are subject to 29 CFR 1910.1200, and must notify the cognizant NYSERDA Project Manager of its intended use, prior to bringing such chemicals on the Center. b) The Contractor shall ensure that all chemicals brought on site are either totally consumed or removed from the site at the end of each deployment. Chemicals must not be stored at Center facilities without the consent of the cognizant NYSERDA Project Manager. c) The Contractor shall take all reasonable cost-effective measures to minimize the amount of waste generated during the course of the work performed under this Agreement. The Contractor shall manage any waste generated while performing work at the Center in accordance with applicable WVSMP procedures and the guidance of the cognizant NYSERDA Project Manager. Contractors shall notify the cognizant NYSERDA Project Manager in advance of activities that have the potential for generating hazardous waste. In addition to any other applicable penalty, the Contractor shall be financially liable for the cleanup of any hazardous materials or wastes necessitated by the Contractor's or any subcontractor's failure to comply with the requirements of this Agreement.

~~C2 of 2~~