1 of 108 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) Day 2 DQO Training

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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)

Day 2 DQO Training CourseModule 2

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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

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Generic Flow Chart

Information IN Actions Information OUT

From Previous Step To Next Step

Information

OUT to

Next Step

Information IN

From Previous

StepActions

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Information

OUT to

Next Step

Information IN

From Previous

StepActions

Added information is presented in bubblesto explain how to implement an action orexplain items to consider.

Generic Flow Chart

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Examples

There are two types of examples found in this training– The general example

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.

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Step Objective:

To clearly define the Problem so that the focus of the Project will be unambiguous

Step 1: State the Problem

Step 4: Specify Boundaries

Step 2: Identify Decisions

Step 3: Identify Inputs

Step 1: State the Problem

Step 5: Define Decision Rules

Step 6: Specify Error Tolerances

Step 7: Optimize Sample Design

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Step 1a - State the ProblemInformation IN Actions Information OUT

From Previous Step To Next StepIdentify the DQO Team and define each member’s roles and responsibilities

Continue activities

Identify the decision makers and define each member’s roles and responsibilities

Identify the Stakeholders and determine who will represent their interests

Planning Meeting

Identify available resources and relevant deadlines

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Continue activities



Planning Meeting

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

Step 1a - State the Problem

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Continue activities



Planning Meeting


DQO Team may include:• Chemist• Hydrogeologist• Engineer• Safety Specialist• Statistician• Modeler• Quality Assurance (QA)/ Quality Control (QC) Specialist• Etc.


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DQO Team Members CS

Name Organization Area of Technical Expertise

Dr. Phil Meyer State University Technical Lead/Facilitator

Deborah Howard A.J. Consulting Regulatory Analysis

Pete Weiss A.J. Consulting Environmental Engineer

Albert Robins A.R. Consulting Radiochemist

Samantha R. Rigley Detection Laboratories, Inc. Chemist

John Soilman A.J. Consulting Geologist

Rusty Rushman A.J. Consulting Risk Assessor

Susan Blackbird A.J. Consulting Statistician

Dan Mansel DOEProject Manager, provide sitehistory

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Continue activities



Planning Meeting


• 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


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Project Activities Budget Contractual Vehicle Milestone Dates

DQO summary report $15,000 Subcontract 4/1/02

Sampling and analysis plan $20,000 Subcontract 6/1/02

Sample analyses $50,000 Subcontract 8/30/02

Data quality assessment $8,000 Subcontract 9/21/02

Decision document $15,000 Subcontract 11/1/02

Available Resources and DeadlinesCS

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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

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Continue activities



Planning Meeting


Decision makers are those that have authorityover the study and are representatives of:• Department of Energy• Environmental Protection Agency• State Regulatory Agency


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Decision Makers CS

Name Organization Role and Responsibility

Dempsey Fitzgerald EPA Federal Regulator

Dan Mansel Department of Energy Project Manager

Jack Nottingham State Office of the Environment State Regulator

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Continue activities



Planning Meeting


Decision Makers:• Seek, consider, and represent the concerns of the Stakeholders• Have the ultimate authority for making final decisions based

on the recommendations of the DQO Team


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Continue activities



Planning Meeting

Identify available resources and relevant deadlinesStakeholders are groups or individuals that will be impacted

by the decisions made as a result of the DQO Process.


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Name Organization Represented By

Citizens for a CleanerCommunity

Local Special Interest Group Tom Ahlgreen

Associated Native Americans Local Native American’s Group Gary Silverhawk

Sierra Club National Special Interest Group Jessica Gonzalez

Mayor/City Council Local Community Martin Larson

Stakeholders CS

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Scoping Process Results

Scoping Process Issues

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

Administrative and logistical elements

Step 1b - State the Problem

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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

CS

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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

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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

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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

CS

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CSRI/FS Borehole Data Radionuclides(Perimeter soil samples)

Sample-Depth from Surface (ft)

A-0 0.07 J 0.54 0.05 U 0.13 U 0.18 U 0.13 U 0.17A-5 0.01 U 0.20 0.04 U 0.53 0.13 U 0.13 U 0.19 JA-25 0.01 U 0.62 0.05 U 0.20 0.18 U 0.12 U 0.40 JA-35 0.01 UJ 0.15 0.03 U 0.78 0.10 U 0.06 U 0.61 b

B-0 0.06 10.53 0.49 3.65 0.28 0.03 1.26B-5 0.01 UJ 0.08 0.05 U 0.18 0.16 U 0.11 U 0.11 UB-25 0.01 U 0.69 0.02 U 0.84 0.09 U 0.11 U 0.55 JB-35 0.00 U 0.18 0.05 U 0.44 0.18 U 0.12 U 0.33 J

C-0 0.43 6.64 0.32 2.58 0.27 0.10 1.42C-5 0.32 11.55 0.43 12.81 1.40 0.15 U 5.77C-25 -0.03 U 0.79 0.04 0.11 0.16 U 0.14 U 0.57C-35 0.01 U 0.20 0.05 0.26 0.17 U 0.11 U 0.57

mean 0.08 2.68 0.13 1.88 0.27 1.00std dev 0.14 4.31 0.17 3.62 0.36 1.56% RSD 189% 161% 127% 193% 131% 156%

U = Not detectedJ = Estimated Concentration

Pu-239/240 (pCi/g)

Eu-152 (pCi/g)

Eu-154 (pCi/g)

Cs-137 (pCi/g) Co-60(pCi/g)

Eu-155 (pCi/g) Sr-90 (pCi/g)

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CSRI/FS Borehole Data Metals(Perimeter soil samples)

Sample-Depth from Surface (ft)

A-0 0.40 U 9.70 6.20A-5 0.40 U 12.00 5.30A-25 0.41 12.00 5.40A-35 0.54 2.60 2.20

B-0 0.04 U 0.84 1.63B-5 0.41 4.50 3.30B-25 0.40 U 6.00 9.60B-35 0.40 U 5.60 3.70

C-0 0.27 U 6.32 4.70C-5 0.44 8.36 16.30C-25 0.49 5.30 9.00C-35 0.56 4.92 3.54

mean 0.40 6.51 5.91std dev 0.13 3.44 4.08% RSD 34% 53% 69%

U = Not detectedJ = Estimated Concentration

Pb (mg/kg)

As (mg/kg)

Cr+6 (mg/kg)

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CSRI/FS Borehole Data Radionuclides(Trench soil samples)

Sample-Depth from Surface (ft)A-5 0.13 U 0.21 0.06 U 0.17 U 0.18 U 0.09 U 0.19 JA-10 1.64 66.00 2.12 88.80 6.60 0.55 4.20A-20 1.43 37.20 1.00 54.20 3.89 0.28 U 2.70A-30 0.39 UJ 14.00 0.52 21.90 1.70 0.18 U 0.92 J

B-5 0.17 U 0.12 0.00 U 0.18 U 0.04 U 0.03 U 0.33 JB-10 3.20 92.40 2.97 124.32 9.24 0.77 5.88B-20 2.00 66.00 1.20 106.00 3.00 0.53 4.10B-30 0.42 U 15.40 0.57 24.09 1.87 0.20 1.01

C-5 -0.13 U 0.11 0.03 U 0.07 J 0.10 U 0.06 U 0.14 UC-10 3.20 130.00 3.71 155.40 11.55 0.96 7.35C-20 3.00 75.00 1.75 138.10 6.81 0.49 5.10C-30 0.67 24.50 0.90 38.33 2.98 0.32 1.61

meana 2.14 59.40 1.32 99.43 4.57 0.43 3.97std dev 0.79 19.75 0.39 42.33 1.99 0.13 1.21% RSD 37% 33% 29% 43% 44% 31% 30%

a. Mean estimated from 20 ft samples onlyU = Not detectedJ = Estimated Concentration

Eu-154 (pCi/g)Eu-155 (pCi/g)

Sr-90 (pCi/g)

Pu-239/240 (pCi/g) Cs-137 (pCi/g)

Co-60 (pCi/g)

Eu-152 (pCi/g)

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CSRI/FS Borehole Data Metals(Trench soil samples)

Sample-Depthfrom Surface(ft)

Cr+6(mg/kg)

Pb(mg/kg)

As(mg/kg)

A-5 0.40 U 9.30 6.70A-10 0.41 U 12.30 6.30A-20 0.41 U 5.90 8.50A-30 0.40 U 7.60 8.60

B-5 0.08 U 8.60 4.10B-10 0.57 7.50 15.20B-20 0.49 6.20 18.30B-30 0.44 8.36 16.30

C-5 0.42 U 6.40 1.90C-10 0.72 U 8.20 11.03C-20 0.62 U 4.30 12.20C-30 0.70 U 8.90 15.05

meana,b

0.51 7.80 10.35

std dev 0.11 2.03 5.18% RSD 21% 26% 50%a. Only data points from –20 ft used in mean estimate for

Cr+6.b. All data points used for mean estimate of As and Pb.U = Not detectedJ = Estimated Concentration

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Areas to be Investigated - Top view

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29.4 mor 97 ft

Process

10 10020 8030 7040 60500

Process

About 30 ft of layback toaccomodate 1.5/1 slope

from 20 ft down

11.2 mor 37 ft

50.25 m, 166 ft

32.3 m, 106 ft

Original Trench ProfileArea to be left at -20 ft

Plan View

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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)

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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

Summary of Spills andReleases (cont.)

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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)

CSSummary of Spills and

Releases (cont.)

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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

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Areas to be investigated:– soil via direct exposure– groundwater

Areas Excluded– Biota (covered by overall site program)– exclude surface water

Current Conditions (cont.) CS

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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

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From Previous Step To Next StepConduct interviews with decision makers and Stakeholders to determine their:

•Objectives

•Requirements (applies to decision makers only)

•Concerns

Specify interview issues

Hold Global Issues Meeting to resolve scoping and interview issues



Continue activities

Step 1c - State the Problem

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•Objectives


•Concerns





Continue activities

Any differences in interviewees’ objectives, requirements or concerns are listed as issues.


Note

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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

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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.

Interview Issues (cont.) CS

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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.

CSInterview Issues (cont.)

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Land Use: – DOE believes land use is will be industrial

– EPA believes land use should be residential

CSInterview Issues (cont.)

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•Objectives


•Concerns





Continue activities

Global Issues Meeting:Resolve any outstanding scoping issues and/or interview issues with decision makers.


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CSTrench Remediation Objectives, Requirements, and Concerns

Responsible Party Objectives Requirements Concerns

John Ahlgreen,Citizens for aCleaner Community

Elimination ofenvironmental risk

Suitability/protectiveness ofcleanup standards.

Dan Mansel, DOERepresentative

Demonstrate sitecompliance or needfor further cleanup

Comply with regulations.

Schedule delays, Cost overruns, Lack of sufficient sample

data

Dempsey Fitzgerald,EPA


Lower overall risk tohuman health and theenvironment.

Lack of sufficient sample data, orcollection of data not suited forrisk assessment.

Jim Hansen,RemediationContractor


Schedule delays, Cost overruns, Lack of sufficient sample

data

Jack Nottingham,State EcologyOffice of theEnvironment


Lower overall risk tohuman health and theenvironment.

Lack of sufficient sampledata, or collection of data notsuited for risk assessment.

Impacts to the localcommunity and stateinterests.

Gary Silverhawk,Associated NativeAmericans

Return of the land toits native state andclean up tobackground levels

Suitability/protectiveness ofcleanup standards.

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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.

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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

Global Issues Meeting (cont.)CS

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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.

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Global Issues Meeting (cont.)

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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.

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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.

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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.

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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.

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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.

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Global Issues Resolutions

Conceptual Site Model

Problem StatementEstimate COPC distributions

Provide rationale for COPC exclusions

Create final list of COPCs with rationale for inclusions

Specify release mechanisms

Identify fate and transport mechanisms

List potential receptors

Discuss decision drivers

Write CSM Summary Narrative

Identify COPCs

Step 1d - State the Problem

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Identify COPCs

Define the total list of COPCs :Identify:

• Source of contamination: Reactor fuel rods• Type of contamination from each source: Fission products• Specific COPCs Am-241, Co-60, Cs-137


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CSExample Trench Remediation -Total List of COPCs for Each Waste Stream

Waste Stream

Known orSuspected

Source(s) ofContamination(e.g., equipment

maintenance,storage)

Type ofContamination

(General)(e.g., petroproduct)

COPCs(Specific)

(e.g., Lead, PCBs)

Water Contaminatedfrom Storage ofRuptured FuelElements in FuelBasin

Fission/activation,uranium,transuranics, anti-corrosion products

Co-60, Cs-137, Eu-152,154,155, Pu-239/240, Sr-90, Sm-151, C-14, H-3,uranium, Cr VI

Primary CoolingWater Overflow intobasin duringrefueling



Soil in Trenchbelow 5 ft

Sludge and potentialpieces of fuelelements fromCleanout of FSB



IncidentalContamination frompossible trenchoverflow, spillageduring sludgedisposal in trench



Perimeter Soilsand 5 ftoverburden

Orchard Sprayingprior toestablishment ofDOE reservation

Lead-arsenatespray

Pb, As

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Identify COPCs

Identify COPC Exclusions:• Develop rationale for the exclusion of any of the COPCs• Document the rationale for any exclusions

Example: - Isotope with short half-life- No health or ecological risk


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Identify COPCs

Consider the following questions:1. Was the compound/element ever used at the site?2. Does the compound react with water and thus no longer exist?3. For waste, does the pH of the matrix degrade the compound?4. Is the compound volatile and thus evaporate?


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COPC Exclusions CS

WasteStream

COPCs Rationale for Exclusion

C-14,

H-3,uranium

Not detected during RI/FS process. Eliminated from further consideration inthe RI/FS.

Sm-151 No standard laboratory method available. Dose consequences negligiblecompared to other COPCs

Cr VIDetected in an occasional sample at very low levels during RI/FS process. Morethan 25x below Hanford background and remdiation goals. Perimeter andtrench soil approximately the same low concentrations.

Pb, As

According to RI/FS data, these metals were not found in quantities exceedingthe site background and/or were not present above regulatory thresholds.There is no evidence of contamination by operations. Perimeter and trench soilapproximately the same low concentrations.

Soil inTrench andSoil inTrenchabove -5 ftandPerimetersoils.

Eu-154, 155According to RI/FS data, these radionuclides were not found in quantitiesexceeding the site background and/or were not present within a factor of 25 ofregulatory thresholds.

Soil inTrench andSoil inTrenchabove -5 ftandPerimetersoils.

Pu-239/240According to RI/FS data, these radionuclides were not found in quantitiesexceeding the site background and/or were not present within a factor of 25 ofregulatory thresholds.

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Identify COPCs

Identify the Final List of COPCs


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Final List of COPCs CS

Waste Stream COPCs Rationale for Inclusion

Soil in Trenchabove -5 ft andperimeter soils.

Co-60, Cs-137,Eu-152, Sr-90,

Soil in Trenchbelow 5 ft

Co-60, Cs-137,Eu-152,Pu-239/240, Sr-90

COPCs found at levels that could impact risk assessmentand evaluation of final end state.

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Identify COPCs

How the release occurred?Still occurring?Single large release?Small release over long time?Stack release of gases?Contaminated debris?


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Release Mechanisms How the COPCs arrived at the facility

– COPCs transported to the soil in the trench in two ways;• Contained in liquid effluents from the reactor fuel storage

basin. The effluent contained soluble and insoluble radionuclides and metals.

• Disposal of sludge trucked from the fuel storage basin.

– The only physical component in the CSM is environmental media (e.g., gravel, sand, and soil)

• The soil has been contaminated by solid and liquid material from the fuel storage basin at various times during the trench’s history

• The physical components of the site include surface and subsurface soils and gravel within the known boundaries of the disposal site

CS

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Identify COPCs

Begin to evaluate the fate & transport of COPCs

Begin to evaluate the distribution of COPCs


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Identify COPCs

Step 1d - State the ProblemUsed to make assumption on the distribution (lateral/vertical) of COPCs

Dependent on:• Types of COPCs expected• How they arrived• Amount of time since the release• Environmental conditions since the release• Effect of natural processes• Wind, weather, erosion, re-charge, etc.

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Identify COPCs

Types of sampling media:• Soil• Concrete• Groundwater• Gravel• Etc.


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Fate and Transport How will/has the fate and transport

mechanisms affect(ed) the COPCs– Unimpeded access is assumed for all sampling

media. Because the site received contaminated water and sludge and has been exposed to weather (precipitation) during its history, transport into the subsurface blow the bottom of the trench is assumed

– To support site confirmation for residential release, the underlying soil is included within the boundaries of the site

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Identify COPCs

Examples of receptors are • Humans• Plants• Animals


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Receptors

Future land use– It is anticipated that the land must be released

for residential use at some future time. Therefore, potential receptor is a resident living on the property.

– For purposes of this project, plant and animal receptors do not need to be considered. They are addressed through other site-wide programs.

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The pathway for exposure via surface contamination and contamination in the vadose zone needs added evaluation

Exposure to contaminants left on site would occur through several pathways;– Inhalation

– Ingestion of crops, water, livestock

– Direct dose from near surface contamination

Potential PathwaysCS

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Data for groundwater wells near the site have indicated contamination potentially attributable to this site

A resident on the site may drill a well and use the water for drinking and irrigation, thus the groundwater pathway must be included

The following figure shows the potential pathway to humans via exposure to the surface and subsurface soil

Potential Pathways (cont.)CS

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CSPotential Receptors (cont.)

Process

Groundwater, Saturated Zone (SZ)

Original SoilSurface

SurfaceContamination

Depth toGroundwater

ExcavationFootprint

Estimate 50%of VadoseZone Soil

Contaminated

Estimate 50%of Vadose

Zone Soil NotContaminated

ContaminatedVadose

Zone (CZ) Depth

UncontaminatedVadose

Zone (UZ) Depth

Well

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Identify COPCs

Spatial and frequency distributions

This is key point for determining the number of samples


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Football Field

One-AcreFootball Field

30'0"

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Spatial Distribution - Football Field

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Probability Density Function

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Identify COPCs

Liquid spill Plume model (decreasing with distance)Burn pit Lateral and vertical heterogeneityTank sludge Lateral homogeneity/vertical heterogeneityFill What information is available about the fill?Concrete Drivers? Air; Water; Contact


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Spatial Surface Soil Sample Results

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Process

Process

Original Trench ProfileArea to be left at -20 ft

PerimeterBorehole

#3

PerimeterBorehole

#2

PerimeterBorehole

#1

TrenchBorehole

#1

TrenchBorehole

#3

TrenchBorehole

#2

10 10020 8030 7040 60500

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Distributions Presumed Spatial Distributions of the COPCs

– The trench received contaminated water from a pipe and concrete structure on one end. However the trench was usually filled to a depth of several feet, so there should be no significant differences in concentration in the soil below the trench floor.

– Because some of the site was covered with clean soil, it cannot be assumed that contamination decreases with depth from the surface. However, from the surface that received the effluent, whether or not that is the current surface, contamination is expected to decrease with depth. The borehole data supports this model; therefore, deeper soils are assigned a lower probability of being contaminated.

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Distributions (cont.)– The probability of contamination will be scaled within a

range bounded by the arbitrary lateral and vertical boundary to be determined during sample optimization (Step 7). This is because the amount of data collected from the RI/FS is not sufficient to define the physical boundaries of the expected residual contamination. The previous RI/FS did not use the DQO Process.

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Frequency DistributionConcentration,

pCi/g ColorNumber of Marbles

1 N/A 02 N/A 03 Clear 94 White 785 Green 2696 Red 3737 Yellow 2258 Blue 439 Black 3

10 N/A 0

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Frequency DistributionCS

Perimeter Cs-137Concentration (pCi/g)

Frequency

0-2 92-4 04-6 06-8 1

8-10 010-12 3

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HistogramCS

0123456789

10

Perimeter Cs-137 Concentration (pCi/g)

Freq

uenc

y

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Histogram (cont.)CS

0123456789

10

0 0.1 0.2 0.3 0.4 0.5

Perimeter Co-60 Concentration (pCi/g)

Fre

qu

en

cy

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CSHistogram (cont.)

0123456789

10

Perimeter Eu-152 Concentration (pCi/g)

Fre

qu

en

cy

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CSHistogram (cont.)

0

1

23

4

5

6

Perimeter Sr-90 Concentration (pCi/g)

Fre

qu

en

cy

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Distribution Curves

Mo = Md = Mn

Normal

Mo Md Mn

Lognormal

M0 = modeMd = medianMn = mean

% of time when x < is high, for small n

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Identify COPCs

Are COPCs co-located? (e.g., based on partition coefficients,pH causing precipitation) real time analysisfor indicator contaminants


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Identify COPCs

Identify driver compounds (e.g., based on greatest risk or movement or half-life)Examine concentration range and compare to action limit(e.g., far below or above action limit, near action level)


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Identify COPCsOverall objectives of the project:

• Is the decision risk based?• Waste characterization based?• Regulatory restraints?• Future land uses?• Pilot study?• Remedial action?• Monitoring effort?• Characterization effort?• All potential data uses/users identified?


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Decision Drivers Future land use

– Effect of residual contamination on human residential receptors was not previously considered

– All parties agreed to use residential land use as the scenario

CS

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Identify COPCs

The CSM narrative summary states clearly the current understanding of the condition of the site


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Identify COPCsUse information gathered from the scoping process,decision maker interviews and the Global Issues Meeting to develop a CSM

The CSM may be presented in the following forms:• Narrative statement• Graphical • Tabular


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CSM Narrative The Trench and the surrounding soil (surface and

underlying) extending laterally up to 30 ft in any direction from the perimeter of the trench and down to a depth of 20 ft constitutes the conceptual model for the contaminated site. It is graphically depicted in the plan view and section view in the following section. – Perimeter side slope soil is defined as soil up to a depth of

-20 ft

– Trench footprint soil is defined as vadose zone soil in the trench footprint from -20 ft to groundwater (approximately 65 ft surface to groundwater)

CS

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CSM Spatial GraphicalCS

Process

Process

5 ft of Uncontaminated Overburden

Side slopeSoils

20 ft level,bottom of theengineered

structure

15 ft of contaminated trench material

50% of Vadose Zone Contaminated (22.5 ft)

50% of Vadose Zone Uncontaminated (22.5 ft)

Ground Water, Saturated Zone

Grade

65 ft

10 10020 8030 7040 60500

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Overview of the Receptor Pathway(CSM) Tabular

PrimarySources

SecondaryRelease

MechanismPathway

RupturedFuel Rods,

reactorcoolant

Sudgefrom

rupturedfuel rods,

dust in FSB

LiquidEffluent

from FSB

CleaningFSB and

Diposing ofSludge

Diposalto Soil

Dust, plantuptake,livestockuptake,humanactivity

MigrationthroughVadose

Zone to GW

Contaminationof foodstuffs

ReceptorHuman Biota

Exposure Route A

rea

Res

iden

tsS

i te

visi

tors

Terr

estr

ial

Aqu

atic

Ingestion X X XInhalationDermal Contact X X X

Ingestion X X XInhalation X X XDermal Contact X X X

Ingestion X X X XInhalationDermal Contact X X X X

SecondarySources

PrimaryRelease

Mechanism

Ground Water,drinking and

irrigating

Resupension

CS

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Identify COPCs

The goal of the DQO Process is to develop a sampling design that will confirm or reject the CSM.


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Problem Statements

The CSM is used to constrain the problem statement(s)

The Problem Statement(s) allows the planning to be focused on issues that must be resolved with data and makes the problem unambiguous

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Identify COPCs

A concise problem statement describes:• The problem as it is currently understood• The conditions that are causing the problem


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Problem Statement Format

General Format: In order to [support decisions for site

remediation/better understand the nature of the waste/establish a basis for materials management] data are required that define [the nature and extent of contamination/the constituents of concern/the source and characteristics of the materials].

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In order to confirm that the NaI survey data can replace High Purity Germanium (HPGe) results for use as Closeout Verification Plan (CVP) variance data, data regarding radiological soil contamination using both methods are needed.

In order to determine the sampling and release requirements for concrete and associated soils, data regarding metal, polychlorinated biphenyls (PCBs) and radiological contamination in concrete and soils are needed.

Problem Statement Examples

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In order to confirm that the on-site in-situ GC/MS analysis can replace method 8260B results for use in final verification of closure, data regarding volatiles using both methods are needed.

In order to determine whether the concrete should be disposed at a TSCA incinerator, data regarding the PCBs in the concrete surface are needed.

Problem Statement Examples (cont.)

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Process knowledge indicates that there would have been low plutonium concentrations in the wastes disposed through the tank and relatively few other radionuclides should be present. Limited sampling of the sludge indicates that plutonium is distributed within strata throughout the tank; however, this distribution is somewhat heterogeneous and ill-defined. Characterization data are required to evaluate the need for an early removal action and, as required, to determine the appropriate methods for (1) removal of the sludge from Tank Y, (2) stabilization and packaging of the waste, and (3) sludge disposal.

‘Typical’ Problem Statement Example

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In order to determine whether the residual soils at the site are contaminated, data regarding potential contaminants in the surface and underlying soils are needed.

Problem Statement CS

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Step 1 Summary Scoping is the most important activity Adequate resources (time, money, people) must be

provided for scoping Adequate resources must be provided for the DQO

Process Identify the decision makers’ objectives, requirements,

and concerns Performing interviews allows the facilitator to

understand each decision maker’s objectives and requirements

Resolving global issues allows technical staff to focus on providing defensible designs

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Global issues include land use and interpretation of regulations

Step 1 Summary (cont.)

Logic for inclusion and exclusion of COPCs must be documented

It is possible to greatly decrease the number of COPCs based on sound technical logic

Remember, if there is no receptor there is no risk CSM is based on scoping The DQO Process goal is to test the CSM CSM allows one to focus on problems that are

resolved by data/information

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Continue activities



Planning Meeting



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•Objectives


•Concerns





Step 1b - State the Problem



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Continue activities

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

Administrative and logistical elements


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Identify COPCs


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End of Module 2

Thank you

Documents

1 of 108 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) Day 2 DQO Training