The EPA 7-Step DQO Process

1. Day 2 DQO Training CourseModule 2 The EPA 7-Step DQO Process Step 1 - State the Problem Presenters: Mitzi Miller and Al Robinson 8:15 AM - 9:30 AM (75 minutes)

2. Terminal Course Objective To be able to develop a list of contaminants of concern, a conceptual site model (CSM), and a problem statement(s) for a specific project

3. Generic Flow Chart Information INActionsInformation OUT From Previous Step To Next Step Information IN From Previous Step Actions Information OUT to Next Step

4. Generic Flow Chart Information INActionsInformation OUT From Previous Step To Next Step Information IN From Previous Step Actions Information OUT to Next Step Added information is presented in bubbles to explain how to implement an action or explain items to consider.

5. CS • The case study that is used to show the flow of the logic. The same case study is used for each step. It is called “Process Effluent Trench” and has the icon in the upper right corner. Examples • There are two types of examples found in this training • The general example

6. Step 1: State the Problem Step 1: State the Problem Step Objective: To clearly define the Problem so that the focus of the Project will be unambiguous Step 2: Identify Decisions Step 3: Identify Inputs Step 4: Specify Boundaries Step 5: Define Decision Rules Step 6: Specify Error Tolerances Step 7: Optimize Sample Design

7. Step 1a - State the Problem Information INActionsInformation OUT From Previous Step To Next Step Identify the DQO Team and define each member’s roles and responsibilities Identify available resources and relevant deadlines Planning Meeting Continue activities Identify the decision makers and define each member’s roles and responsibilities Identify the Stakeholders and determine who will represent their interests

8. Step 1a - State the Problem Information INActionsInformation OUT From Previous Step To Next Step Identify the DQO Team and define each member’s roles and responsibilities Identify available resources and relevant deadlines • The DQO Team is the technical group that • will develop the DQOs for the project • The number of members will be directly related • to the size and complexity of the problem Planning Meeting Continue activities Identify the decision makers and define each member’s roles and responsibilities Identify the Stakeholders and determine who will represent their interests

9. Step 1a - State the Problem Information INActionsInformation OUT From Previous Step To Next Step Identify the DQO Team and define each member’s roles and responsibilities • DQO Team may • include: • Chemist • Hydrogeologist • Engineer • Safety Specialist • Statistician • Modeler • Quality Assurance (QA)/ Quality Control (QC) Specialist • Etc. Identify available resources and relevant deadlines Planning Meeting Continue activities Identify the decision makers and define each member’s roles and responsibilities Identify the Stakeholders and determine who will represent their interests

10. CS DQO Team Members

11. Step 1a - State the Problem Information INActionsInformation OUT From Previous Step To Next Step Identify the DQO Team and define each member’s roles and responsibilities Identify available resources and relevant deadlines Planning Meeting Continue activities Identify the decision makers and define each member’s roles and responsibilities • Stipulate the anticipated budget, available • personnel, and contractual vehicles to be used • Enumerate any deadlines for completion of • the study and any intermediate deadlines that • may need to be met Identify the Stakeholders and determine who will represent their interests

12. CS Available Resources and Deadlines

13. Budget and Milestones • As is the case in the example, budgets and schedules are often set without any systematic planning • It is preferred that the DQO Process be performed well before the budget and schedule are established • Budgets for implementing the DQO Process are a must • The results of the DQO Process can then be used to set the remaining project schedule and budget

14. Step 1a - State the Problem Information INActionsInformation OUT From Previous Step To Next Step Identify the DQO Team and define each member’s roles and responsibilities • Decision makers are those that have authority • over the study and are representatives of: • Department of Energy • Environmental Protection Agency • State Regulatory Agency Identify available resources and relevant deadlines Planning Meeting Continue activities Identify the decision makers and define each member’s roles and responsibilities Identify the Stakeholders and determine who will represent their interests

15. CS Decision Makers

16. Step 1a - State the Problem Information INActionsInformation OUT From Previous Step To Next Step Identify the DQO Team and define each member’s roles and responsibilities Identify available resources and relevant deadlines Planning Meeting Continue activities Identify the decision makers and define each member’s roles and responsibilities • Decision Makers: • Seek, consider, and represent the concerns of the Stakeholders • Have the ultimate authority for making final decisions basedon the recommendations of the DQO Team Identify the Stakeholders and determine who will represent their interests

17. Step 1a - State the Problem Information INActionsInformation OUT From Previous Step To Next Step Identify the DQO Team and define each member’s roles and responsibilities Identify available resources and relevant deadlines Stakeholders are groups or individuals that will be impacted by the decisions made as a result of the DQO Process. Planning Meeting Continue activities Identify the decision makers and define each member’s roles and responsibilities Identify the Stakeholders and determine who will represent their interests

18. CS Stakeholders

19. Step 1b - State the Problem Information INActionsInformation OUT From Previous Step To Next Step • Scoping Process Results: • Collect site history, process knowledge, • Summarize existing analytical data • Specify areas to be investigated • Summarize all recorded spills and releases • Document applicable regulations • Current housekeeping practices • Current local environmental conditions Scoping Process Results Scoping Process Issues Administrative and logistical elements

20. CS Remedial Action Soil Process Knowledge • Process Effluent Trench used 1952-1965 • Received mixed waste effluent from a uranium fueled graphite reactor retention basin • In 1965 the trench received water and sludge from cleanup of the reactor retention basin • Subsequent to receiving the sludge, a 5 ft layer of clean fill was placed on top of the trench in 1966, bringing it to grade

21. CS Example (cont.) • An interim Record of Decision (ROD) was signed and in 1998 an Remedial Design Report (RDR)/Remedial Action Work Plan (RAWP) was prepared to establish action levels (ALs) and preliminary COPCs • Data was obtained during RI/FS investigations to estimate the vertical extent of migration of COPCs inside and outside the trench

22. CS Summary of Existing Data • Summary of existing radioactive and non-radioactive contaminant data • See following 4 tables • Samples from 3 Boreholes were obtained from inside the trench and from the perimeter of the trench • Samples were obtained from 3 depths in each borehole • 7 Radioactive constituents were measured • Three non-radiological constituents were measured

23. CS Summary of Existing Data (cont.) • Data from Boreholes Inside and Outside the Trench • Pu-239/240, Cs-137, Co-60, Eu-152, Eu-154, Eu-155, Sr-90 detected above instrument background • In Trench - samples show radionuclide concentration generally decreasing with depth • Out of Trench - samples show radionuclide concentration exhibiting no trend with depth • Chromium VI, arsenic and lead detected above instrument detection limit • In Trench - concentration of metals show no trend related to depth • Out of Trench - concentration of metals show no trend with depth

24. CS RI/FS Borehole Data Radionuclides(Perimeter soil samples)

25. CS RI/FS Borehole Data Metals(Perimeter soil samples)

26. CS RI/FS Borehole Data Radionuclides(Trench soil samples)

27. CS RI/FS Borehole Data Metals(Trench soil samples)

28. CS Areas to be Investigated - Top view

29. CS Summary of Spills and Releases • Trench is a rectangle 106 ft (32.3 m) long and 37 ft (11.2 m) wide • Excavation will proceed with a 1.5/1 side-slope perimeter around the trench footprint • Estimated working zone with trench centered within is 166 ft (50.3 m) by 97 ft (29.4 m) • Area of Trench is 3,922 ft2 • Area of Perimeter Zone is 12,180 ft2 (excluding Trench area)

30. CS Summary of Spills andReleases (cont.) • Volume of Trench, -5 to -20 ft, is 1,654 yd3 • Volume of Perimeter Zone, 1.5/1 slope from20 ft depth, is 4,507 yd3 (excluding Trench area) • Volume of 5 ft of Overburden is 551 yd3 • It is assumed that the 5 ft overburden and removed side-slope soil is not contaminated above regulatory limits. • Excavation progress will be monitored

31. CS Summary of Spills andReleases (cont.) • Process Knowledge indicates the • Pu 239/240, Eu-152, 154, 155, Sr-90, Cs-137, C-14, H-3, Sm-151, Co-60, Cr VI • Arsenic and lead were added since the site had been an orchard and have been sprayed with lead-arsenates • 5 ft Cover and side-slope soils will be removed and set aside for use as fill • The trench will be excavated to the bottom of the engineered structure (-20ft)

32. CS Current Conditions • Housekeeping practices • Input lines to trench blocked to prevent use • Site Posted as an underground contamination area • Vegetation above trench limited to grasses • Site conditions and local environment • Avg. rainfall ~10 in./yr • Groundwater at ~65 ft below grade • Temperatures range 0 to 110°F • No cover or water collection system

33. CS Current Conditions (cont.) • Areas to be investigated: • soil via direct exposure • groundwater • Areas Excluded • Biota (covered by overall site program) • exclude surface water

34. CS Scoping Issues • The degree and extent of soil contamination reported from the RI/FS is questionable • There are different opinions as to whether multiple constituents of interest exist and whether the constituents are present above regulated levels at the site

35. Step 1c - State the Problem Information INActionsInformation OUT From Previous Step To Next Step • Conduct interviews with decision makers and Stakeholders to determine their: • Objectives • Requirements (applies to decision makers only) • Concerns Continue activities Specify interview issues Scoping Process Results Scoping Process Issues Hold Global Issues Meeting to resolve scoping and interview issues

36. Step 1c - State the Problem Information INActionsInformation OUT From Previous Step To Next Step • Conduct interviews with decision makers and Stakeholders to determine their: • Objectives • Requirements (applies to decision makers only) • Concerns Note Any differences in interviewees’ objectives, requirements or concerns are listed as issues. Continue activities Specify interview issues Scoping Process Results Scoping Process Issues Hold Global Issues Meeting to resolve scoping and interview issues

37. CS Interview Issues • Uncertainty in the borehole data: Regulators expressed concern that since the borehole data is limited, the CSM may not be accurate, which will then impact the sampling design

38. CS Interview Issues (cont.) • Suitability/protectiveness of cleanup standards:Current Federal regulations regarding cleanup levels have been questioned by local stakeholders (special interest groups) as to their degree of protectiveness. Current special interest groups have argued that contamination, at any level, poses an unnecessary and unacceptable threat to human health and the environment. These special interest groups have asserted that DOE has a moral obligation to remove all detectable contamination in order to ensure that the surrounding community and wildlife is protected.

39. CS Interview Issues (cont.) • Schedule delays, cost overruns, lack of sufficient sample data:DOE has expressed concerns over the involvement of special interests, particularly those who would require that the DOE perform potentially unneeded cleanup operations that are well beyond the scope and intent of the law. DOE has also expressed a concern that the operation be managed within the schedule and costs for which the project has been assigned. There is also a need to collect data that will be sufficient for its intended purpose; site closure/risk assessment input, or, designation of the waste for cleanup and disposal.

40. CS Interview Issues (cont.) • Land Use: • DOE believes land use is will be industrial • EPA believes land use should be residential

41. Step 1c - State the Problem Information INActionsInformation OUT From Previous Step To Next Step • Conduct interviews with decision makers and Stakeholders to determine their: • Objectives • Requirements (applies to decision makers only) • Concerns Global Issues Meeting: Resolve any outstanding scoping issues and/or interview issues with decision makers. Continue activities Specify interview issues Scoping Process Results Scoping Process Issues Hold Global Issues Meeting to resolve scoping and interview issues

42. CS

43. CS Global Issues Meeting • Scoping Issue: • The degree and extent of soil contamination reported from the RI/FS is questionable • Resolution: • Currently available historical information (existing data) was collected with the intent of supporting the conceptual model for all liquid disposal sites according to RI/FS considerations. However, such characterization data are not sufficient to support a decision for site closure or a decision to conduct additional remedial action if deemed necessary.

44. CS Global Issues Meeting (cont.) • Scoping Issue: • Regulators expressed concern that since the borehole data is limited, the CSM may not be accurate, which may impact the sampling design • Resolution: • Data will be obtained at the completion of remedial action to adequately describe the end state of the site

45. CS Global Issues Meeting (cont.) • Scoping Issue: • Suitability/protectiveness of cleanup standards: Implementation of current cleanup dose standards are questioned by the interest groups. The concern is that the compliance with the standards are not adequately demonstrated by dose risk scenarios. • Resolution: • The State and Federal agencies have explained the risk assessment process to the interest groups. Compliance with these risk levels will be protective. Based on more information related to the scenarios used in the risk assessment process, the interest groups indicated that the approach was logical.

46. CS Global Issues Meeting (cont.) • Interview Issue: • Schedule delays, cost overruns, lack of sufficient sample data: DOE has expressed concerns over the involvement of special interests, particularly those who would require that DOE perform potentially unneeded cleanup operations that are well beyond the scope and intent of the law. DOE has also expressed a concern that the operation be managed within the schedule and costs (presented later in this example) for which the project has been assigned. There is also a need to collect data that will be sufficient for its intended purpose; site closure/risk assessment input or designation of the waste for cleanup and disposal.

47. CS Global Issues Meeting (cont.) • Resolution: • DOE will rely on the DQO Process to determine the most cost-effective and technically defendable means for collection of samples. Furthermore, DOE will be using the DQO Process to document agreement of the sampling strategy with the regulators and local community as a means of reducing liability and future litigation. The Sampling and Analysis Plan (SAP) generated from the DQO effort will result in data collection sufficient for its intended purpose.

48. CS Global Issues Meeting (cont.) • Interview Issue: • Data will not be of sufficient quality for risk assessment: Regulators are concerned that previous data are not of the quality to support risk assessment • Resolution: • Regulators will be participants in the DQO Process which defines the data and quality requirements. In addition, they may take split samples at the same time sampling is performed.

49. CS Global Issues Meeting (cont.) • Interview Issue: • Conflicting land uses (industrial vs. residential): Regulators believe the land use is residential. An industrial scenario would change input parameters and may result in allowing higher concentrations to remain in the soil. DOE believes the future land use should be industrial.

50. CS Global Issues Meeting (cont.) • Resolution: • For all government facilities, a federal facility agreement (FFA) is signed between the EPA/State and the federal agency that owns the site (e.g., DOE or military). By law, this agreement indicates that the federal agency owning the site can designate the land use or agree to negotiate the land use. • Since final land use will not be established until some time in the future, DOE agreed to remediate to potential future residential land use. However, DOE retained the option of achieving that goal through institutional controls if cost became unrealistic for the site.