Survey Report for On-Site Confirmatory Sample Analysis at ... · AAR Confirmatory Sample Analysis 2 5204-SR-02-0 and sampling data for the remediated areas were provided to the NRC

SURVEY REPORT FOR ON-SITE CONFIRMATORY SAMPLE ANALYSIS

AT AAR MANUFACTURING, INC. LIVONIA, MICHIGAN

Evan M. Harpenau

Prepared for the U.S. Nuclear Regulatory Commission

August 2015

Further dissemination authorized to the NRC only; other requests shall be approved by the originating facility

or higher NRC programmatic authority.

AAR Confirmatory Sample Analysis 5204-SR-02-0



FINAL REPORT

Prepared by Evan M. Harpenau

AUGUST 2015

Prepared for the U.S. Nuclear Regulatory Commission

Prepared by ORAU under the Oak Ridge Institute for Science and Education contract, number DE-AC05-06OR23100, with the U.S. Department of Energy under interagency agreement (NRC FIN No. F-1244) between the U.S. Nuclear Regulatory Commission and the U.S. Department of Energy.

AAR Confirmatory Sample Analysis i 5204-SR-02-0

CONTENTS

FIGURES ........................................................................................................................................................... ii TABLES .............................................................................................................................................................. ii 1. INTRODUCTION ....................................................................................................................................... 1 2. SITE DESCRIPTION ................................................................................................................................. 2 3. OBJECTIVES ................................................................................................................................................ 3 4. APPLICABLE SITE GUIDELINES ........................................................................................................ 3 5. PROCEDURES ............................................................................................................................................ 4

5.1 Reference System .............................................................................................................................. 4 5.2 Soil Sampling ...................................................................................................................................... 4

5.2.1 Waste Characterization of the 0–1 Meter Layer ................................................................... 4 5.2.2 Characterization of the Remaining 1–2 Meter Layer ........................................................... 5 5.2.3 Confirmatory Soil Sample Analyses ....................................................................................... 5

6. SAMPLE ANALYSIS AND DATA INTERPRETATION ................................................................. 5 7. FINDINGS AND RESULTS ..................................................................................................................... 7

7.1 Document/Data Review .................................................................................................................. 7 7.1.1 Laboratory Software Configuration ....................................................................................... 7 7.1.2 Field Laboratory Data Comparison ....................................................................................... 7 7.1.3 Project Completion Report ..................................................................................................... 8 7.1.4 Revised Project Completion Report ...................................................................................... 9

7.2 Reference System .............................................................................................................................. 9 7.3 Soil Sampling ...................................................................................................................................... 9 7.4 Analytical Comparison of Split Samples ...................................................................................... 10

8. COMPARISON OF RESULTS WITH RELEASE GUIDELINES ................................................. 12 9. SUMMARY .................................................................................................................................................. 12 10. REFERENCES ......................................................................................................................................... 14 APPENDIX A. FIGURES APPENDIX B. TABLES APPENDIX C. SURVEY AND ANALYTICAL PROCEDURES APPENDIX D. MAJOR INSTRUMENTATION

AAR Confirmatory Sample Analysis ii 5204-SR-02-0

FIGURES

Figure A-1. Grids of the Western Parcel ................................................................................................... A-1 Figure A-2. Confirmation of Grid Structure in the Western Parcel ...................................................... A-2

TABLES

Table B-1. On-site Comparison of Gamma Spectroscopy Results for Th-232 in the 1–2 Meter Layer at the AAR Manufacturing, Inc. Site .............................................................................B-1

Table B-2. On-site Comparison of Gamma Spectroscopy Results for Th-232 in the Waste Material at the AAR Manufacturing, Inc. Site .........................................................................B-2

Table B.3. Off-site Comparison of Th-232 Gamma Spectroscopy Results for the Split Samples Collected Exclusively by Solutient ............................................................................................B-4

AAR Confirmatory Sample Analysis 1 5204-SR-02-0



1. INTRODUCTION

The AAR site, currently owned and occupied by AAR Manufacturing, Inc., was once owned by the

former Brooks and Perkins Company, which manufactured products containing thorium alloys from

1957 to 1981. In 1959, a license was issued to the Brooks and Perkins Company to possess and use

15,000 pounds of thorium. A master magnesium-thorium alloy containing 40% thorium was used in

process operations to produce alloy products such as HM21 (ingots), consisting of approximately

2% thorium, and HK31 (sheets) of approximately 3% thorium (BKA 1996). The master alloy was

heated, melted, and poured into molds. The castings were removed from the molds, cut, and

trimmed after the material had cooled. The scrap metal was recovered, heated and melted, rolled

into sheets that were further heated and formed, and then pickled in an acid bath. The final product

was sanded, ground, and brushed prior to shipping.

In 1970, Brooks and Perkins conducted a radiological survey to support termination of their license

with the Atomic Energy Commission (AEC), predecessor to the U.S. Nuclear Regulatory

Commission (NRC). The radiological survey indicated that residual radioactive material in the

process areas and rooms was below the 1970 AEC guidelines for unrestricted release. However, that

survey also identified contamination outside of the process areas. Reportedly, contaminated material

from the walkway outside of the Melt Room Area had been buried on site, but this was not

substantiated during the initial survey effort (BKA 1996). In 1971, Brooks and Perkins requested

and received termination of its license.

AAR purchased the Brooks and Perkins property in 1981. AAR manufactures specialty items

(e.g., aluminum cargo containers and related structural supports) for the aircraft industry. In 1994,

the NRC conducted an inspection of the site, including interior building surfaces and exterior land

areas, and determined that there was thorium contamination in both interior and exterior locations.

AAR retained B. Koh and Associates, Inc. (BKA) to perform site characterization surveys in 1996

and 1999 and to perform limited remediation in January 2000 and late 2006/early 2007. Final survey


and sampling data for the remediated areas were provided to the NRC in March 2000. No data were

presented after remediation in late 2006/early 2007 (BKA 2000 and PEC 2007).

AAR submitted a dose analysis based on the site characterization results for the NRC’s review.

This dose analysis was prepared as a means to demonstrate that the eastern parcel would satisfy

unrestricted use dose criteria and that the western parcel (the subject of this report) would satisfy

requirements for restricted use. AAR subsequently revised the approach for the western parcel to

meet criteria for unrestricted use, including proposed remediation of additional grids containing

the highest residual thorium concentrations (AAR 2013). The NRC staff then conducted an

independent dose assessment and concluded that the 1999 characterization data in conjunction

with the AAR commitment to remediate the selected 100 m2 grids were sufficient for the purpose

of a final status survey to assess the dose to an average member of the critical group (for

conformity with the unrestricted use criterion of 10 CFR 20.1402) (NRC 2013).

In order to satisfy the unrestricted release criterion of 10 CFR 20.1402, AAR’s contractor, Solutient

Technologies, Inc. (herein referred to as Solutient), has remediated the 0–1 meter layer of specific

exterior grids that were selected based on the characterization data (Figure A-1). In addition to the

remediation, Solutient performed real-time characterization sampling and analysis of soils in the

1–2 meter layer (AAR 2013).

2. SITE DESCRIPTION

The AAR Manufacturing site is located in Livonia, Michigan approximately 20 miles northwest of

Detroit, and is bordered by light commercial developments to the north, Inkster Road to the east,

railroad tracks to the south, and a commercial truck facility to the west. The current site

configuration is made up of eastern and western parcels and consists of a small outbuilding, gravel

parking area, and a facility previously used for offices and manufacturing (PEC 2007).The content in

this report addresses the de-vegetated land and gravel areas associated with the western parcel.


3. OBJECTIVES

The objectives of the confirmatory sample analyses were to perform in-process independent

analyses and independent contractor field data reviews, and to generate independent radiological

data for use by the NRC in evaluating the accuracy and adequacy of the licensee’s procedures and

final survey soil sample concentration results.

4. APPLICABLE SITE GUIDELINES

Historical site use and characterization data indicated that the primary radionuclides of concern

(ROCs) to be thorium-228 (Th-228), Th-230, and Th-232 (BKA 1999). The NRC determined that it

was reasonable to assume that Th-228 and Th-232 were in equilibrium and that Th-230 was present

in an activity concentration ratio of 2:1 with both Th-228 and Th-232. Thus, the calculated total

thorium concentration for a given sample would be 4.0 times that of Th-232 (NRC 2013). AAR

proposed a DCGLW for the 1–2 m layer of an average concentration of 20 picocuries per gram

(pCi/g), total thorium, or 5 pCi/g of Th-232 in order to satisfy the criterion for unrestricted use

(NRC 2013). The results of the NRC staff’s independent dose assessment concluded that the

proposed DCGLW was acceptable. Since Th-232 is more readily quantified in the field via the Ac-228

daughter, all soil sample results were compared to a derived concentration guideline level (DCGLW)

of 5 pCi/g for Th-232.

On-site analysis determined the concentration of Th-232 on an individual sample basis. Each result

for the 1–2 meter soil layer was then used in a weighted calculation which included inputs from the

1999 AAR characterization data along with Solutient’s 2014 sample results to determine if

remediation efforts were successful in maintaining an average Th-232 concentration below the

5 pCi/g DCGLW for the site’s western parcel.


5. PROCEDURES

The on-site confirmatory sample analysis activities were conducted during four phases that included

May 14–16, June 1–6, June 16–27, and July 29–30, 2014, in accordance with a project-specific

confirmatory sample analysis plan approved by the NRC, the ORAU Radiological and Environmental

Survey Procedures Manual, the ORAU Radiological and Environmental Analytical Laboratory Procedures

Manual, and the ORAU Environmental Services and Radiation Training Quality Program Manual (ORAU

2014a, ORAU 2014b ORAU 2015, and ORAU 2014c). Independent confirmatory activities included

contractor document and field data reviews, observing contractor field activities, analysis of split soil

characterization samples from predetermined grid locations, and the collection and analysis of

excavated contaminated soil originating within the western parcel of the AAR site.

5.1 REFERENCE SYSTEM

Solutient subcontracted Ambit Land Surveyors, Inc. to recreate the grid system used during the 1999

characterization effort. The original grid was based on a localized coordinate system presumed to be

consistent with the Michigan State Plane Coordinate System, NAD 1983 (meters). Grids were

sub-divided into equally sized quadrants along the X and Y axes. ORAU used global positioning

system (GPS) equipment based on the Michigan State Plane Coordinate System to record geospatial

data with a real-time accuracy of an approximate 0.5 meter radius to evaluate grid placement.

5.2 SOIL SAMPLING

ORAU observed the contractor collecting samples using procedures consistent with the methods

described in the 1999 characterization report and approved by NRC prior to implementation.

5.2.1 Waste Characterization of the 0–1 Meter Layer

Samples collected from contaminated material being excavated and sent for off-site disposal were

comprised of a homogenized aliquot of soil taken directly from every fifth excavator bucket and

from the last bucket loaded into the disposal containers. ORAU and the contractor collected

independent samples from locations immediately adjacent to one another in the excavator bucket.

Samples were independently prepared and analyzed for comparative evaluation. These sample

analyses were performed for the purpose of confirming that regulations regarding the transportation

of radiologically contaminated material were satisfied and not for characterizing soils for site release.


5.2.2 Characterization of the Remaining 1–2 Meter Layer

Once the 0–1 meter layer was excavated, soil samples from the 1–2 meter layer were collected by the

contractor using an electric auger with a six inch diameter bit. Each sample was homogenized by the

contractor and an aliquot was taken by ORAU for independent sample preparation and analysis.

Each sample was then given a unique identification label associating it with the grid and quadrant it

had been collected from. The confirmatory sample grids of the western parcel that were evaluated

by on-site analysis are shown in Figure A-1.

5.2.3 Confirmatory Soil Sample Analyses

All on-site confirmatory samples were dried and large objects and debris such as rocks, concrete,

and asphalt were removed prior to analysis. ORAU also incorporated the use of a quarter-inch sieve

for each sample to remove larger items and normalize the soil medium for samples while the

contractor only performed a visual inspection and removed larger items by hand. Following

preparation, ORAU filled 16-ounce plastic containers for direct gamma spectroscopy counting using

a portable gamma spectroscopy system (Note: the contractor only utilized exactly 200.3 grams of

soil then placed it into an eight ounce metal can for direct counting.) On-site analysis determined the

Th-232 concentration in soil through the by quantifying the 911 keV photopeak from Ac-228

(a daughter of Th-232 assumed to be in equilibrium with Th-232).

In addition after ORAU had demobilized from the site, the NRC requested that the remediation

contractor collect, homogenize, and then split soil samples from 20 to 25 locations across the

western parcel of the AAR site. Ultimately 21 split samples were placed into ORAU-provided

containers and shipped to the ORAU Radiological and Environmental Analytical Laboratory

(REAL) in Oak Ridge, Tennessee for laboratory analysis.

6. SAMPLE ANALYSIS AND DATA INTERPRETATION

On-site analysis was accomplished through the use of a portable gamma spectroscopy system.

ORAU results were assessed with the corresponding contractor data and supporting documentation

to determine if compliance with the release criterion had been accurately and adequately

demonstrated. The samples received at the REAL in Oak Ridge, Tennessee were analyzed in


accordance with the ORAU Radiological and Environmental Analytical Laboratory Procedures Manual

(ORAU 2015). All analytical results were reported in units of pCi/g.

Soil data comparisons were planned for a two phased approach. First, the approved confirmatory

analysis plan stated that compliance with the release criterion would include the evaluation of split

sample results using the duplicate error ratio (DER), also known as the normalized absolute

difference. In order to perform the DER evaluation, sample results must include the associated

analytical uncertainty. DER ≤3 indicates that, at a 99+% confidence interval, the duplicate sample

results do not differ significantly when compared to their respective one standard deviation (sigma)

uncertainty. Analytical results below or near the minimum detectable concentration (MDC) are not

typically evaluated using DER.

The following equation presents the DER calculation.

𝐷𝐷𝐷𝐷𝐷𝐷 = |𝑃𝑃 − 𝑆𝑆|

�𝑈𝑈𝑃𝑃2 + 𝑈𝑈𝑆𝑆2

Where:

P = Contractor primary sample result S = ORAU split sample result UP = Contractor primary sample one sigma uncertainty US = ORAU split sample one sigma uncertainty

Relative percent difference (RPD) was used as a substitute for evaluating duplicate samples when the

analytical data did not contain the analytical uncertainty required to perform the DER calculation.

As with the application of DER, analytical results near or below method MDC are not typically

evaluated via RPD since minor differences in concentration can cause a variance greater than the

acceptable parameters of the comparison. The acceptable criteria for the RPD evaluation states that

variance between duplicate sample results should be less than 25% using the following equation

(DOE 2010):

𝐷𝐷𝑃𝑃𝐷𝐷 = |𝑆𝑆 − 𝑃𝑃|𝑃𝑃 𝑋𝑋 100

Where: P = Contractor primary sample result S = ORAU split sample result


The second phase evaluated the mean and 95% standard deviation of the Th-232 concentration in

the 1–2 meter layer between the ORAU and Solutient reported results (ORAU 2014a).

7. FINDINGS AND RESULTS

Data and field-implementation reviews identified several issues needing correction in order for the

contractor to accurately and adequately demonstrate compliance with the release criterion. All

identified issues were communicated to the NRC site representative(s) for resolution with the

remediation contractor.

7.1 DOCUMENT/DATA REVIEW

7.1.1 Laboratory Software Configuration

While on-site, ORAU personnel reviewed the contractor’s gamma spectroscopy reports and found

that the nuclide identification (NID) report was not generating data comparable to the ORAU

report. The contractor’s NID report did not include the actinium-228 (Ac-228) 911 keV energy

peak, the surrogate for Th-232, as a positively identified radionuclide when concentrations were

above minimum detectable activity (MDA). Instead, the contractor was using the MDA analysis

page to report the Th-232 concentrations. The NID report provides the counting error associated

with the sample concentration which is necessary to perform the DER evaluation. Since the

contractor’s NID report was not positively identifying the targeted 911 keV energy peak, counting

errors were not being made available, thus preventing ORAU from being able to compare the data

sets as originally planned. ORAU personnel, the contractor, and NRC site representative located the

setting in the processing software responsible for eliminating the target peak in the NID report. The

issue was corrected during the July 29–30, 2014, site visit. After making the correction in the

software, ORAU was of the understanding that the contractor would re-run each gamma

spectroscopy report which would provide the necessary adjustments to their reported data. Further

discussion on this issue is provided in Section 7.1.3.

7.1.2 Field Laboratory Data Comparison

Determinations for whether remediation was necessary in a particular grid were to be made based

upon an individual grid’s impact on the running average for the entire western parcel rather than

average concentration within an individual grid. While on site, ORAU observed the contractor


making remediation decisions based upon the latter, causing a significant increase to waste disposal

costs. ORAU personnel promptly notified the NRC site representative and, with NRC concurrence,

assisted the contractor in making the necessary adjustments.

7.1.3 Project Completion Report

ORAU reviewed the initial completion report (ST 2014a). The assessment of the report identified

several concerns regarding format and quality of the reported data. The first concern related to the

continued omission of the NID report within the larger gamma spectroscopy report when the

corresponding sample contained a Th-232 concentration above the MDA. This had a direct impact

on the comparison of sample data due to the absence of a calculated counting uncertainty and will

be discussed in greater detail in Section 7.4.

The second issue identified was inconsistencies between tabulated data in Attachment 7 and the

gamma spectroscopy reports in Attachment 9 of the project completion report. Upon further

review, ORAU determined that in some cases, if the MDA value was larger than the corresponding

concentration result, then the MDA was recorded in the report tables rather than the actual result

together with the MDA. In other instances, it was observed that the MDA for some samples

increased from the 1–2 pCi/g to more than 4 pCi/g for the 911 keV energy peak. ORAU

determined that the contractor’s inconsistent and increased MDAs corresponded with varying

sample geometries resulting from the use of a measured mass, 200.3 g, and a typical sample count

time limited to fifteen minutes. It was explained to the contractor while on site that increasing the

sample mass, count time, or both would have resulted in a lower MDA.

Data reviews also identified that the contractor’s “Average Total Thorium Concentration”

calculation was being performed using the straight arithmetic average of all sample data. However,

because the number of samples from individual grids varied between 4 and 8, the contractor, NRC,

and ORAU had developed a weighted average formula for use when combining the characterization

data from both 1999 and 2014. The weighted average total thorium concentration was necessary to

ensure that each 100 m2 grid would be weighted equally by normalizing those grids with eight

samples to grids where fewer samples had been collected and thereby preventing a systematic bias to

the actual thorium concentration in soil.


After a discussion involving the inconsistencies of the contractor’s reported data on May 4, 2015,

AAR and their contractor agreed to revise the sample data such that concentrations would be

represented in the NID report when there was positive identification of the Ac-228 911 keV peak,

and that the MDA value would be reported when sample concentrations were not distinguishable

from background. A detailed list of documentation concerns were submitted to the NRC in a formal

document review record (ORAU 2014d).

7.1.4 Revised Project Completion Report

Two recurring issues were identified in the revised completion report (ST 2015). First, 23% of

samples with Th-232 concentrations above the MDA and some even above the DCGLW for Th-232

were still omitted from the NID report (e.g., samples from Grids 216-3 and 216-4). Secondly,

instead of reporting the MDA value when sample concentrations were not distinguishable from

background, the contractor reported the actual value in the nuclide MDA report. Though these

issues were expected to have been resolved after the May 4, 2015, conference call, the nuclide MDA

report contained enough information about each sample to calculate the average Th-232

concentration and determine whether the western parcel met the release criteria.

7.2 REFERENCE SYSTEM

ORAU personnel were able to verify that the local coordinate system implemented by Solutient was

consistent with the Michigan State Plane Coordinate System, NAD 1983. Confirmation was

achieved using GPS equipment capable of achieving an accuracy of 0.5 meters. In addition, the

subcontracted land surveyors returned during the May14 visit to confirm their grid locations. ORAU

is satisfied that the grid structure is consistent with that of the 1999 effort (Figure A-2).

7.3 SOIL SAMPLING

Several issues were identified during the in-process confirmatory observation activities. The most

significant issues are discussed below.

The first issue was identified when confirmatory personnel observed that the contractor had

stopped using a unique sample identification system to track sample results between site inspections.

The NRC representative informed the contractor that without a unique sample identifier, analytical


results could not be cross-referenced to their respective sample locations. The contractor promptly

corrected the issue by reverting back to the sample identification system used during a previous site

visit.

ORAU also observed that the contractor was not establishing a protective barrier at sample

locations to separate the ground surface from the soil that was to be incorporated in the sample.

ORAU personnel informed the NRC site representative of the importance of keeping the two media

separate so as to maintain a representative sample from the 1–2 meter layer. The NRC then

discussed the issue with the contractor who agreed to place a barrier on top of the ground with a

hole in the middle to allow for collection of the one meter thick soil core.

The next issue was observed during waste preparation and involved insufficient homogenizing of

soil prior to sampling, which led to an incorrect determination of the concentration of

contamination in the waste container. Off-site disposal criteria required sampling of the waste

material to ensure that the dump trailers used for waste conveyance were placarded properly, and

that the average concentration of total thorium did not exceed the Department of Transportation

criteria of


for comparison of split sample results when the DER could not be calculated. The RPD was

calculated between the contractor’s gamma spectroscopy result and the corresponding ORAU

concentration (or replicate sample) for each sample pair. Tables B.1 and B.2 provide a comparison

of the contractor and ORAU soil sample data for the 1–2 meter layer and waste material analyzed

while on site.

Analytical results of samples split between ORAU and the contractor are relatively consistent

with one another. Although the split sample aliquots were taken from a larger, well-mixed sample,

the site presented a relatively complex and heterogeneous matrix. Therefore, it was not always

possible to create a homogenized sample capable of producing two identical aliquots. Some

amount of variation between split sample results was therefore expected to occur. To

accommodate this fact, split sample results were compared immediately while on site. When

variations between results were observed, ORAU obtained the contractor’s sample for analysis on

the ORAU mobile gamma spectroscopy system. Prior to doing so, ORAU used one of the

contactor’s containers along with a certified standard to calibrate the ORAU gamma spectrometer

to the same geometry used by the contractor. In these cases, ORAU identified that the variations

in Th-232 concentrations resulted from the physical differences between the two samples and not

as a result of sample preparation or analytical methodology. Overall, the split sample comparison

shows the contractor’s data to be adequately representative of the population. Results from the

contractor and REAL analysis of the 21 replicate samples are provided in Table B.3 for

comparison. The comparison of these data also shows that the contractor’s data adequately

represent the sample population.

ORAU calculated the current average concentration of Th-232 in each grid and subsequently the

western parcel by combining the equally weighted 1999 and 2014 Solutient characterization data

divided by the total number of samples collected. The average concentration of Th-232 in the

western parcel for the 1–2 meter soil layer to-date was calculated to be 2.3 pCi/g.


8. COMPARISON OF RESULTS WITH RELEASE GUIDELINES

The mean of the Th-232 concentration in the 1–2 meter layer determined by ORAU was compared

to the results reported by Solutient. Even though confirmatory gamma spectroscopy analysis

identified nine post-remediation samples in the grids that were still above the 5 pCi/g DCGLW, the

collective mean concentration of Th-232 for Solutient’s samples collected in the 1–2 meter layer of

the western parcel at the AAR Manufacturing, Inc. site, to-date, is below the release criterion of 5

pCi/g.

9. SUMMARY

At the NRC’s request, ORAU conducted confirmatory sample analysis activities for 25 of the 112

grids in the western parcel of the AAR Manufacturing, Inc. site. On-site activities were performed

during the periods of May 14–16, June 1–6, June 16–27, and July 29–30, 2014. During the course of

sampling the 1–2 meter layer, Solutient collected samples from 32 grids overall. In addition to the

characterization samples from the 1–2 meter layer grids, 49 contaminated soil samples were analyzed

to ensure conformance with regulations regarding transportation as well as acceptance criteria for

the waste acceptance facility.

While on site, ORAU observed the complete cycle of sample collection and analysis performed by

the contractor. As previously discussed, there were certain instances that required the contractor to

make changes to their processes in order to more accurately produce and report thorium

concentrations both in individual grids and the western parcel as a whole. The analyst’s basic

understanding of the instrument was adequate to produce data in a routine climate. However, it was

clear that on-site contractor personnel did not possess the ability to make any significant changes to

the system through software applications. Fortunately, necessary changes were able to be made

through consultation with contractor’s off-site staff and ORAU analysts.

ORAU was able to confirm that the contractor’s portable gamma spectroscopy system was

functioning properly and was accurately calibrated. The certified standard and geometry used for

calibrating contractor instrumentation was verified by ORAU through direct analysis and review of

quality control procedures. Analytical quality control was performed daily to an adequate set of

criteria.


While the contractor’s sample preparation procedures differed slightly from those conducted by

ORAU, they appeared sufficient in consistently providing representative samples for analysis.

Conversely, it was noted that more optimal detection limits could have been achieved by increasing

the sample mass and/or increasing count times. The higher detection limits provided some difficulty

with regards to the direct comparison of split sample results and at times were greater than the

common 10 to


10. REFERENCES

AAR 2013. AAR Western Parcel Strategic Waste Excavation, Soils Management and Site Restoration Remedial Work Plan. AAR Corp. Wood Dale, IL August 7.

BKA 1996. Site Characterization Report Former Brooks and Perkins, Inc. Site AAR Manufacturing Group, Inc. Livonia, MI. B. Koh and Associates, Inc. Owings Mills, Maryland. April.

BKA 1999. Site Characterization Report – Phase II Former Brooks and Perkins, Inc. Site AAR Manufacturing Group, Inc. Livonia, MI. B. Koh and Associates, Inc. Owings Mills, Maryland. April.

BKA 2000. Site Summary of Final Survey and Sampling Data for the Former Brooks and Perkins, Inc. Site AAR Manufacturing Group, Inc. Livonia, MI. B. Koh and Associates, Inc. Owings Mills, Maryland. April.

DOE 2010. Quality Systems for Analytical Services. Revision 2.6. U.S. Department of Energy. November.

NRC 2013. Safety Evaluation Report Work Plan For Remediation to Unrestricted Use of the AAR Site, Western Parcel (Inkster Road, Livonia, Michigan). U.S. Nuclear Regulatory Commission. ML13291A287. December 30.

ORAU 2014a. Final—Project-Specific Plan for On-site Confirmatory Sample Analysis at AAR Manufacturing, Inc., Livonia, Michigan. DCN: 5204-PL-02-0. Oak Ridge Associated Universities. Oak Ridge, Tennessee. May 13.

ORAU 2014b. ORAU Radiological and Environmental Survey Procedures Manual. Oak Ridge Associated Universities. Oak Ridge, Tennessee. April 10.

ORAU 2014c. Environmental Services and Radiation Training Quality Program Manual. Oak Ridge Associated Universities. Oak Ridge, Tennessee. December 18.

ORAU 2014d. Review of the Project Completion Report and Request for Approval of Unrestricted Use Designation for the AAR Manufacturing, Inc. Site. DCN: 5204-DR-01-0. Oak Ridge Associated Universities. Oak Ridge, Tennessee. November 13.

ORAU 2014e. Radiation Protection Manual. Oak Ridge Associated Universities. Oak Ridge, Tennessee. August.

ORAU 2014f. Health and Safety Manual. Oak Ridge Associated Universities. Oak Ridge, Tennessee. October 21.

ORAU 2015. ORAU Radiological and Environmental Analytical Laboratory Procedures Manual. Oak Ridge Associated Universities. Oak Ridge, Tennessee. May 7.

PEC 2007. Final Site Remediation Report for the Former Brooks &Perkins Site (AAR Manufacturing). Prepared by Partners Environmental Consulting, Inc. Solon, Ohio April 11.


ST 2014a. Project Completion Report and Request for Approval of Unrestricted Use Designation. Prepared by Solutient Technologies, LLC for the AAR Corporation. North Canton, Ohio. Received from NRC September 15.

ST 2014b. Soils Blending to Achieve Waste Acceptance Criteria. Prepared by Solutient Technologies, LLC for the AAR Corporation. North Canton, Ohio. Received from NRC June 24.

ST 2015. Project Completion Report and Request for Approval of Unrestricted Use Designation. Rev. 1. Prepared by Solutient Technologies, LLC for the AAR Corporation. North Canton, Ohio. May 18.


APPENDIX A

FIGURES


Figure A-1. Grids of the Western Parcel


Figure A-2. Confirmation of Grid Structure in the Western Parcel


APPENDIX B

TABLES

AAR Confirmatory Sample Analysis B-1 5204-SR-02-0

Table B-1. On-site Comparison of Gamma Spectroscopy Results for Th-232

in the 1–2 Meter Layer at the AAR Manufacturing, Inc. Site

Grid Quadrant Sample ID

Result (pCi/g) RPD DER ORAU AAR

Sample Uncert. Sample Uncert. 94 1 94-01 2.16 —b 1.69 —a 28% —a 94 2 94-02 1.34 0.17 1.07 —a 26% —a 94 3 94-03 0.20 —b -1.92 —a -110% —a 94 4 94-04 0.47 —b -0.44 —a -207% —a 122 1 122-1 1.30 0.16 3.77 —a 66% —a 122 2 122-2 0.94 0.11 0.31 —a 201% —a 122 3 122-3 0.21 —b 2.05 —a 90% —a 122 4 122-4 0.49 0.10 0.52 —a 6.2% —a 156 1 156-1 4.64 0.41 4.38 1.08 5.9% 0.22 156 2 156-2 4.88 0.40 4.23 1.07 15% 0.57 156 3 156-3 7.81 0.55 8.92 1.45 13% 0.72 156 4 156-4 0.96 0.20 -1.35 —a -171% —a 157 1 157-1 9.86c 0.47 16.43d 2.00 40% 3.20 157 2 157-2 6.41 0.43 6.68 1.37 4.1% 0.19 157 3 157-3 31.78c 1.17 21.67d 2.34 47% 3.87 157 4 157-4 4.73 0.37 2.49 —a 90% —a 216 1 216-1 -0.11 —b 1.80 —a 106% —a 216 2 216-2 3.42 0.27 2.83 —a 21% —a 216 3 216-3 5.17c 0.40 6.74 —a 23% —a 216 4 216-4 6.13c 0.45 7.36 —a 17% —a

aSoftware setting in the analysis program was eliminating the target peak from the NID report. As a result, no uncertainty was reported because the concentration was recorded from the MDA report for the 911 keV photopeak from Ac-228. The DER could not be determined.

bUncertainty values were not reported. The nuclide concentration was force-calculated by the gamma spectroscopy software. cReported concentration reflects a sample collected from two meters below the surface after excavation of the 1–2 meter layer. dAAR sample was reanalyzed to verify its reported concentration. DER of reanalysis not exceed the acceptable range of


Table B-2. On-site Comparison of Gamma Spectroscopy Results for Th-232 in the Waste Material at the AAR Manufacturing, Inc. Site

Truck/Trailer Sample ID Result (pCi/g)

RPD DER ORAU AAR Sample Uncert. Sample Uncert.

131/— 060314-1 1.72 0.23 2.2 —a 22% —a 131/— 060314-2 14.73 0.99 15.5 —a 5.1% —a 142/— 060314-3 32.04 1.84 30.7 —a 4.4% —a 132/— 060314-4 12.28 0.88 12.9 —a 5.0% —a 132/— 060414-1 10.78 0.78 4.1 —a 162% —a 131/— 060414-2 11.68 0.78 14.2 —a 18% —a

131/1 and 2 060514-1 13.14 0.85 NR — — — 132/29A 061714-1 17.75 1.03 24.6 —a 28% —a 132/29B 061714-2 13.19 0.92 11.4 —a 16% —a

131/1 061714-3 13.92 1.01 12.4 —a 12% —a 131/2 061714-4 6.74 0.52 4.9 —a 38% —a

132/29A 061714-5 17.69 0.94 10.5 —a 68% —a 132/29B 061714-6 16.77 0.89 9.7c —a 73% —a

131/1 061714-7 7.51 0.43 3.1c —a 142% —a 131/2 061714-8 15.27 1.13 4.7b —a 223% —a

132/29A 061914-1 12.33 0.72 6.50 —a 90% —a 132/29B 061914-2 4.84 0.41 4.58 —a 5.8% —a

109/1 061914-3 8.93 0.65 9.06 —a 1.4% —a 109/2 061914-4 6.37 0.52 7.95 —a 20% —a

132/29A 061914-5 10.05 0.66 4.35 —a 131% —a 132/29B 061914-6 7.05 0.57 6.63 —a 6.2% —a

109/1 061914-7 4.73 0.45 2.94 —a 61% —a 109/2 061914-8 5.05 0.45 6.54 —a 23% —a

132/29A 062014-1 3.48 0.37 1.16 —a 201% —a 132/29B 062014-2 1.97 0.28 0.91 —a 117% —a

109/1 062014-3 8.16 0.60 7.48 —a 9.1% —a 109/2 062014-4 13.69 0.84 14.81 —a 7.6% —a

132/29A 062014-5 8.85 0.60 7.68 —a 15% —a 132/29B 062014-6 12.64 0.80 6.44 —a 96% —a

109/1 062014-7 11.18 0.73 8.53 —a 31% —a 109/2 062014-8 8.58 0.60 9.83 —a 13% —a 109/1 062314-1 7.05 0.52 4.63 1.68 52% 1.37 109/2 062314-2 10.79 0.76 18.86 2.79 43% 2.79

142/29A 062314-3 15.85 0.89 13.39 2.24 18% 1.02 142/29B 062314-4 16.54 0.79 16.25 2.19 1.8% 0.13

109/1 062314-5 15.15 1.05 7.92b —a 91% —a


Table B-2. On-site Comparison of Gamma Spectroscopy Results for Th-232 in the Waste Material at the AAR Manufacturing, Inc. Site

Truck/Trailer Sample ID Result (pCi/g)


109/2 062314-6 18.57 0.96 15.93 2.32 17% 1.05 142/29A 062314-7 8.16 0.59 13.39 —a 39% —a 142/29B 062314-8 16.79 0.83 14.02 2.24 20% 1.16

109/1 062414-1 9.88 0.50 6.68 —a 48% —a 109/2 062414-2 11.11 0.70 3.39 —a 228% —a 109/1 062514-1 (157-3) 4.75 0.38 3.90 —a 22% —a

132/29A 062514-2 (217/247) 22.88 1.31 16.70 —a 37% —a 109/2 062514-3 (123) 17.00 1.04 11.02 —a 54% —a

132/29B 062514-4 (217/247) 23.18 1.06 13.94b —a 66% —a 132/29A 062514-5 22.35 1.06 NR — — —

109/1 062514-6 9.03 0.66 NR — — — 132/29B 062514-7 17.43 0.98 NR — — —

109/2 062514-8 11.02 0.70 NR — — — aSoftware setting in the analysis program was eliminating the target peak from the NID report. As a result, no uncertainty was reported because concentration was recorded from the MDA report for the 911 keV photopeak from Ac-228. DER could not be determined

bAAR sample was reanalyzed to verify its reported concentration. RPD of reanalysis confirmed sample concentration was within the acceptable range of 25%.

cAAR sample was reanalyzed to verify its reported concentration. RPD of reanalysis exceeded the acceptable range of 25%. NR=AAR data was not recorded. Note: It is normal for there to be a large RPD between samples with concentrations lower than or near minimum detectable capabilities.


Table B.3. Off-site Comparison of Th-232 Gamma Spectroscopy Results for the Split Samples Collected Exclusively by Solutient

Grid Quadrant Sample ID Result (pCi/g)


247 1 5204S0040 0.39 0.06 0.50 —a 22% —a 217 2 5204S0041 9.97 0.80 9.19 1.58 8.5% 0.44 187 3 5204S0042 5.13 0.47 3.38 1.05 52% 1.52 123 4 5204S0043 0.32 0.06 0.92 —a 65% —a 189 1 5204S0044 1.06 0.12 -0.07 —a 1,614% —a 158 4 5204S0045 5.64 0.47 9.46 1.49 40% 2.45 125 4 5204S0046 0.34 0.06 1.35 —a 75% —a 265 2 5204S0047 1.19 0.13 3.38 —a 65% —a 284 2 5204S0048 0.31 0.06 1.00 —a 69% —a 99 1 5204S0049 0.27 0.05 0.62 —a 56% —a 101 2 5204S0050 0.28 0.06 -1.52 —a 118% —a 283 1 5204S0051 0.93 0.11 2.14 —a 57% —a 265 3 5204S0052 2.35 0.22 3.63 —a 35% —a 76 4 5204S0053 0.45 0.08 1.09 —a 59% —a 188 2 5204S0054 0.30 0.06 0.07 —a 329% —a 370 4 5204S0055 2.81 0.30 2.28 —a 23% —a 37 1 5204S0056 0.42 0.06 0.25 —a 68% —a 369 4 5204S0057 0.60 0.10 -0.87 —a 169% —a 74 1 5204S0058 0.38 0.06 -1.10 —a 135% —a 36 2 5204S0059 0.40 0.07 2.48 —a 84% —a 98 1 5204S0060 0.57 0.10 2.16 —a 74% —a

aSoftware setting in the analysis program was eliminating the target peak from the NID report. As a result, no uncertainty was reported because concentration was recorded from the MDA report for the 911 keV photopeak from Ac-228.

Note: It is normal for there to be a large RPD between samples with concentrations lower than or near minimum detectable capabilities.


APPENDIX C SURVEY AND ANALYTICAL PROCEDURES

AAR Confirmatory Sample Analysis C-1 5204-SR-02-0

C.1. PROJECT HEALTH AND SAFETY

ORAU performed all survey activities in accordance with the ORAU Radiation Protection Manual, the

ORAU Health and Safety Manual, and the ORAU Radiological and Environmental Survey Procedures Manual

(ORAUe, ORAU 2014f, and ORAU 2014b). Should ORAU have identified a hazard not covered in

the ORAU Radiological and Environmental Survey Procedures Manual or the project’s work-specific hazard

checklist, work would not have been initiated or continued until it was addressed by an appropriate

job hazard analysis and hazard controls.

The proposed survey and sampling procedures were evaluated to ensure that any hazards inherent to

the procedures themselves were addressed in current job hazard analyses. Additionally, prior to

performing work, a pre-job briefing and walkdown to identify hazards present were completed and

discussed with field personnel.

C.2. CALIBRATION AND QUALITY ASSURANCE

Calibration of all field instrumentation was based on standards/sources, traceable to National

Institute of Standards and Technology (NIST).

Field survey and laboratory activities were conducted in accordance with procedures from the

following ORAU documents:

• ORAU Radiological and Environmental Survey Procedures Manual (ORAU 2014b)

• ORAU Radiological and Environmental Analytical Laboratory Procedures Manual (ORAU 2015)

• ORAU Environmental Services and Radiation Training Quality Program Manual (ORAU 2014c)

The procedures contained in these manuals were developed to meet the requirements of

U.S. Department of Energy (DOE) Order 414.1D.

Quality control procedures include:

• Daily instrument background and check-source measurements to confirm that equipment

operation is within acceptable statistical fluctuations

• Participation in Mixed-Analyte Performance Evaluation Program, NIST Radiochemistry

Intercomparison Testing Program, and Intercomparison Testing Program Laboratory


Quality Assurance Programs

• Training and certification of all individuals performing procedures

• Periodic internal and external audits

C.3. SURVEY PROCEDURES

C.3.1 SURFACE SOIL SAMPLING

Soil samples were collected from the 1–2 meter layer using an auger in conjunction with an electric

drill. The soil was then transferred into a clean 5-gallon bucket and homogenized by Solutient

personnel under the observation of the NRC and/or ORAU. ORAU and Solutient then collected a

split sample of the homogenized soil. ORAU’s split samples were transferred into a 1-gallon plastic

sealable bag or 0.5-liter plastic sample container. The samples were sealed and labeled using the

Solutient naming convention.

C.3.2 SAMPLE PREPARATION

Prior to analysis, the sample was dried, when necessary, and then packed into a 0.5-liter Marinelli

beaker.

C.4. RADIOLOGICAL ANALYSIS

C.4.1 GAMMA SPECTROSCOPY

Samples were analyzed as received, mixed, crushed, and/or homogenized as necessary, and a portion

sealed in a 0.5-liter Marinelli beaker or other appropriate container. The quantity placed in the

container was chosen to reproduce the calibrated counting geometry. Net material weights were

determined and the samples counted using intrinsic germanium detectors coupled to a pulse height

analyzer system. Background and Compton stripping, peak search, peak identification, and

concentration calculations were performed using the computer capabilities inherent in the analyzer

system. All total absorption peaks (TAPs) associated with the ROCs were reviewed for consistency

of activity. Minimum detectable concentrations for each radionuclide are available upon request.

Spectra were also reviewed for other identifiable TAPs.


Radionuclidea TAP (MeV) MDC (pCi/g) Th-232b 0.911 0.14

aSpectra were also reviewed for other identifiable TAPs. bThe Ac-228 911.1 keV peak is used for the quantification of Th-232, assuming secular equilibrium. MDC = minimum detectable concentration TAP = total absorption peak

C.5. DETECTION LIMITS

Detection limits, referred to as MDCs, were based on the 95% confidence level via the

NUREG-1507 method. Because of variations in background levels, measurement efficiencies, and

contributions from other radionuclides in samples, the detection limits differ from sample to sample

and instrument to instrument.


APPENDIX D MAJOR INSTRUMENTATION

AAR Confirmatory Sample Analysis D-1 5204-SR-02-0

The display of a specific product is not to be construed as an endorsement of the product or its manufacturer by the author or his employer.

D.1. SCANNING AND MEASUREMENT INSTRUMENT/DETECTOR

COMBINATIONS

D.1.1 GAMMA

Ludlum NaI Scintillation Detector Model 44-10, Crystal: 5.1 cm × 5.1 cm (Ludlum Measurements, Inc., Sweetwater, TX) coupled to: Ludlum Ratemeter-scaler Model 2221 (Ludlum Measurements, Inc., Sweetwater, TX) coupled to: Trimble Data Logger (Trimble Navigation Limited, Sunnyvale, CA)

D.2. LABORATORY ANALYTICAL INSTRUMENTATION

Broad Energy High Purity Germanium Detector CANBERRA Model No: BEGE3825 S/N:6104 Used in conjunction with:

Canberra’s ISOXSHLD Lead Shielding Canberra’s Inspector 2000 MCA Canberra’s Gamma Software (Canberra, Meriden, CT)

High-Purity, Extended Range Intrinsic Detector CANBERRA/Tennelec Model No: ERVDS30-25195 (Canberra, Meriden, CT) Used in conjunction with: Lead Shield Model G-11 (Nuclear Lead, Oak Ridge, Tennessee) and Multichannel Analyzer Canberra’s Gamma Software Dell Workstation (Canberra, Meriden, CT)

High-Purity, Intrinsic Detector Model No. GMX-45200-5 CANBERRA Model No: GC4020 (Canberra, Meriden, CT) Used in conjunction with: Lead Shield Model G-11 Lead Shield Model SPG-16-K8 (Nuclear Data)

AAR Confirmatory Sample Analysis D-2 5204-SR-02-0

Multichannel Analyzer Canberra’s Gamma Software Dell Workstation (Canberra, Meriden, CT)

Documents

Survey Report for On-Site Confirmatory Sample Analysis at ... · AAR Confirmatory Sample Analysis 2 5204-SR-02-0 and sampling data for the remediated areas were provided to the NRC