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3.3.11 Site preparation prior to remediation actions

Contents
3.3.11.1 Introduction
3.3.11.2 Consent for characterization survey
3.3.11.3 Property boundaries
3.3.11.4 Physical characteristics
3.3.11.4.1 Land areas
3.3.11.4.2 Structures on site
3.3.11.5 Clearing to provide access
3.3.11.5.1 Land areas
3.3.11.5.2 Structures on site

3.3.11.1 Introduction

Site preparation involves obtaining consent for performing the survey, establishing the property boundaries, evaluating the physical characteristics of the site, accessing surfaces and land areas of interest, and establishing a reference coordinate system. Site preparation may also include removing equipment and materials that restrict access to surfaces. The presence of furnishings or equipment will restrict access to building surfaces and add additional items that the survey should address.

3.3.11.2 Consent for characterization survey

When facilities or sites are not owned by the organization performing the surveys, consent from the site or equipment owner should be obtained before conducting the surveys. All appropriate local, state, and federal officials as well as the site owner and other affected parties should be notified of the survey schedule. Section 2.4.7 discusses consent for access of a site.

3.3.11.3 Property boundaries

Property boundaries may be determined from property survey maps furnished by the owners or from plat maps obtained from city or county tax maps. Large-area properties and properties with obscure boundaries or missing survey markers may require the services of a professional land surveyor.

If the radiological survey is only performed inside buildings, a tax map with the buildings accurately located will usually suffice for site/building location designation.

3.3.11.4 Physical characteristics

The physical characteristics of the site will have a significant impact on the complexity, schedule, and cost of a survey. These characteristics include the number and size of structures, type of building construction, wall and floor penetrations, pipes, building condition, total area, topography, soil type, and ground cover. In particular, the accessibility of structures and land areas (see Section 2.4.9 and Section 3.3.2.3) has a significant impact on the survey effort. In some cases survey techniques (e.g., in situ gamma spectrometry discussed in Sections 3.3.7, 3.4.4 and 3.6.1.3 can preclude or reduce the need to gain physical access or use intrusive techniques. This should be considered during survey planning.

3.3.11.4.1 Land areas

Depending upon site processes and operating history, the radiological survey may include varying portions of the land areas. Potentially contaminated open land or paved areas to be considered include storage areas (e.g., equipment, product, waste, and raw material), liquid waste collection lagoons and sumps, areas downwind (based on predominant wind directions on an average annual basis, if possible) of stack release points, and surface drainage pathways. Additionally, roadways and railways that may have been used for transport of radioactive or contaminated materials that may not have been adequately contained could also be potentially contaminated.

Buried piping, underground tanks, sewers, spill areas, and septic leach fields that may have received contaminated liquids are locations of possible contamination that may necessitate sampling of subsurface soil (see Section 3.4). Information regarding soil type (e.g., clay, sand) may provide insight into the retention or migration characteristics of specific radio-nuclides. The need for special sampling by coring or split-spoon equipment should be anticipated for characterization surveys.

If radioactive waste has been removed, surveys of excavated areas will be necessary before backfilling. If the waste is to be left in place, subsurface sampling around the burial site perimeter to assess the potential for future migration may be necessary.
Additionally, potentially contaminated rivers, harbours, shorelines, and other outdoor areas may require survey activities including environmental media (e.g., sediment, marine biota) associated with these areas.

3.3.11.4.2 Structures on site

Building design and condition will have a marked influence on the survey efforts. The time involved in conducting a survey of building interior surfaces is essentially directly proportional to the total surface area. For this reason the degree of survey coverage decreases as the potential for residual activity decreases. Judgment measurements and sampling, which are performed in addition to the measurements performed for the non-parametric tests, are recommended in areas likely to have accumulated deposits of residual activity. As discussed in Section 3.3.2.9, Section 3.3.10.5 and Section 3.10, judgment measurements and samples are compared directly to the appropriate DCGL.

The condition of surfaces after decontamination may affect the survey process. Removing contamination that has penetrated a surface usually involves removing the surface material. As a result, the floors and walls of decontaminated facilities are frequently badly scarred or broken up and are often very uneven. Such surfaces are more difficult to survey because it is not possible to maintain a fixed distance between the detector and the surface. In addition, scabbled or porous surfaces may significantly attenuate radiations – particularly alpha and low-energy beta particles. Use of monitoring equipment on wheels is precluded by rough surfaces, and such surfaces also pose an increased risk of damage to fragile detector probe faces. These factors should be considered during the calibration of survey instruments; NRC report NUREG-1507 provides additional information on how to address these surface conditions [USNRG-1997]. The condition of the building should also be considered from a safety and health standpoint before a survey is conducted. A structural assessment may be needed to determine whether the structure is safe to enter.

Expansion joints, stress cracks, and penetrations into floors and walls for piping, conduit, and anchor bolts, etc., are potential sites for accumulation of contamination and pathways for migration into sub-floor soil and hollow wall spaces. Drains, sewers, and septic systems can also become contaminated. Wall/floor interfaces are also likely locations for residual contamination. Coring, drilling, or other such methods may be necessary to gain access for survey. Intrusive surveying may require permitting by local regulatory authorities. Suspended ceilings may cover areas of potential contamination such as ventilation ducts and fixtures.

Exterior building surfaces will typically have a low potential for residual contamination. However, there are several locations that should be considered during survey planning. If there are roof exhausts, roof accesses that allow for radioactive material movement, or the facility is proximal to the air effluent discharge points, the possibility of roof contamination should be considered. Because roofs are periodically resurfaced, contaminants may be trapped in roofing material, and sampling this material may be necessary. Roof drainage points such as drip-lines along overhangs, downspouts, and gutters are also important survey locations. Wall penetrations for process equipment, piping, and exhaust ventilation are potential locations for exterior contamination. Window ledges and outside exits (doors, doorways, landings, stairways, etc.) are also building exterior surfaces that should be addressed.

3.3.11.5 Clearing to provide access

In addition to the physical characteristics of the site, a major consideration is how to address inaccessible areas that have a potential for residual radioactivity. Inaccessible areas may need significant effort and resources to adequately survey. This section provides a description of common inaccessible areas that may have to be considered. The level of effort expended to access these difficult-to-reach areas should be commensurate with the potential for residual activity. For example, the potential for the presence of residual activity behind walls should be established before significant effort is expended to remove drywall.

3.3.11.5.1 Land Areas

If ground cover needs to be removed or if there are other obstacles that limit access by survey personnel or necessary equipment, the time and expense of making land areas accessible should be considered. In addition, precautionary procedures need to be developed to prevent spreading surface contamination during ground cover removal or the use of heavy equipment.

Removal or relocation of equipment and materials that may entail special precautions to prevent damage or maintain inventory accountability should be performed by the property owner whenever possible. Clearing open land of brush and weeds will usually be performed by a professional land-clearing organization under subcontract arrangements. However, survey personnel may perform minor land-clearing activities as needed.

An important consideration prior to clearing is the possibility of bio-uptake and consequent radiological contamination of the material to be cleared. Special precautions to avoid exposure of personnel involved in clearing activities may be necessary. Initial radiological screening surveys should be performed to ensure that cleared material or equipment is not contaminated.

The extent of site clearing in specific areas depends primarily on the potential for radioactive contamination existing in those areas where:

  1. The radiological history or results of previous surveys do not indicate potential contamination of an area (it may be sufficient to perform only minimum clearing to establish a reference coordinate system).
  2. Contamination is known to exist or a high potential for contamination necessitates completely clearing an area to provide access to all surfaces.
  3. New findings as the survey progresses may indicate that additional clearing be performed.

Open land areas may be cleared by heavy machinery (e.g., bulldozers, bush-hogs, and hydro-axes). However, care should be exercised to prevent relocation of surface contamination or damage to site features such as drainage ditches, utilities, fences, and buildings. Minor land clearing may be performed using manually operated equipment such as brush-hooks, power saws, knives, and string trimmers. Brush and weeds should be cut to the minimum practical height necessary to facilitate measurement and sampling activities (approximately 15 cm). Care should be exercised to prevent unnecessary damage to or removal of mature trees or shrubs.

Potential ecological damage that might result from an extensive survey should be considered. If a survey is likely to result in significant or permanent damage to the environment, appropriate environmental analyses should be conducted prior to initiating the survey. In addition, environmental hazards such as poison ivy, ticks carrying Lyme disease, and poisonous snakes, spiders, or insects should be noted. These hazards can affect the safety and health of the workers as well as the schedule for performing the survey.

3.3.11.5.2 Structures on site

Structures and indoor areas should be sufficiently cleared to permit completion of the survey. Clearing includes providing access to potentially contaminated interior surfaces (e.g., drains, ducting, tanks, pits, ceiling areas, and equipment) by removing covers, disassembly, or other means of producing adequate openings.

Building features such as ceiling height, construction materials, ducts, pipes, etc., will determine the ease of accessibility of various surfaces. Scaffolding, cranes, lifts, or ladders may be necessary to reach some surfaces, and dismantling portions of the building may be required.

The presence of furnishings and equipment will restrict access to building surfaces and add additional items that the survey should address. Remaining equipment indirectly involved in the process may need to be dismantled in order to evaluate the radiological status, particularly of inaccessible parts of the equipment. Removing or relocating certain furnishings, such as lab benches and hoods, to obtain access to potentially contaminated floors and walls may also be necessary. The amount of effort and resources dedicated to such removal or relocation activities should be commensurate with the potential for contamination. Where the potential is low, a few spot-checks may be sufficient to provide confidence that covered areas are free of contamination. In other cases, complete removal may be warranted.

Piping, drains, sewers, sumps, tanks, and other components of liquid handling systems present special difficulties because of the inaccessibility of interior surfaces. Process information, operating history, and preliminary monitoring at available access points will assist in evaluating the extent of sampling and measurements included in the survey.

If the building is constructed of porous materials (e.g., wood, concrete) and the surfaces were not sealed, contamination may be found in the walls, floors, and other surfaces. It may be necessary to obtain cores of these surfaces for laboratory analysis.

Another accessibility problem is the presence of contamination beneath tile or other floor coverings. This often occurs because the covering was placed over contaminated surfaces, or the joints in tile were not sealed to prevent penetration. The practice in some facilities has been to “fix” contamination (particularly alpha emitters) by painting over the surface of the contaminated area. Thus, actions to obtain access to potentially contaminated surfaces, such as removing wall and floor coverings (including paint, wax, or other sealer) and opening drains and ducts, may be necessary to enable representative measurements of the contaminant. If alpha radiation or very low energy beta radiation is to be measured, the surface should be free of overlying material, such as dust and water, which may significantly attenuate the radiations.