The EPA 7-Step DQO Process

1. DQO Training Course Day 2Module 9 The EPA 7-Step DQO Process Step 1 - State the Problem Presenter: Sebastian Tindall 60 minutes

2. Objective Based on comprehensive Scoping, to be able to develop, for a specific project: 1. a list of Contaminants of Potential Concern, 2. a conceptual site model (CSM), 3. a problem statement(s)

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. 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

6. 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

7. 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 Administrative and logistical elements Continue activities

8. 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 Scoping Process Results Scoping Process Issues Specify interview issues Scoping Process Results Scoping Process Issues Hold Global Issues Meeting to resolve scoping and interview issues

9. Step 1d - State the Problem Information INActionsInformation OUT From Previous Step To Next Step Identify COPCs Provide rationale for COPC exclusions Create final list of COPCs with rationale for inclusions Scoping Process Results Scoping Process Issues Global Issues Resolutions Specify release mechanisms Conceptual Site Model Identify fate and transport mechanisms List potential receptors Problem Statement Estimate COPC distributions Discuss decision drivers Write CSM Summary Narrative

10. 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

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 • 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

12. 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

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 • Have the ultimate authority for making final decisions basedon the recommendations of the DQO Team: • Federal Facility • 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. 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 Identify the Stakeholders and determine who will represent their interests

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 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

17. 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

18. 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

19. 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

20. Concise Statement of the Problem Step 1d - State the Problem Information INActionsInformation OUT From Previous Step To Next Step What are the COPCs? How did COPCs arrive at site? Develop Conceptual Site Model How has fate & transport affected site? What is distribution of COPCs at site? What are the decision drivers: (risk? regulatory limits? etc.)

21. Step 1d - State the Problem Information INActionsInformation OUT From Previous Step To Next Step Identify COPCs Provide rationale for COPC exclusions Create final list of COPCs with rationale for inclusions • Define the total list of COPCs : • Identify: • Source of contamination: Reactor fuel rods • Type of contamination from each source: Fission products • Specific COPCs Sr-90, Cs-137, etc. Scoping Process Results Scoping Process Issues Global Issues Resolutions Specify release mechanisms Conceptual Site Model Identify fate and transport mechanisms List potential receptors Problem Statement Estimate COPC distributions Discuss decision drivers Write CSM Summary Narrative

22. Step 1d - State the Problem Information INActionsInformation OUT From Previous Step To Next Step Identify COPCs Provide rationale for COPC exclusions Create final list of COPCs with rationale for inclusions Scoping Process Results Scoping Process Issues Global Issues Resolutions Specify release mechanisms • 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 Conceptual Site Model Identify fate and transport mechanisms List potential receptors Problem Statement Estimate COPC distributions Discuss decision drivers Write CSM Summary Narrative

23. Step 1d - State the Problem Information INActionsInformation OUT From Previous Step To Next Step Identify COPCs Provide rationale for COPC exclusions Create final list of COPCs with rationale for inclusions Scoping Process Results Scoping Process Issues Global Issues Resolutions Specify release mechanisms 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? Conceptual Site Model Identify fate and transport mechanisms List potential receptors Problem Statement Estimate COPC distributions Discuss decision drivers Write CSM Summary Narrative

24. Step 1d - State the Problem Information INActionsInformation OUT From Previous Step To Next Step Identify COPCs Provide rationale for COPC exclusions Create final list of COPCs with rationale for inclusions Scoping Process Results Scoping Process Issues Global Issues Resolutions Specify release mechanisms Conceptual Site Model Identify fate and transport mechanisms Identify the Final List of COPCs List potential receptors Problem Statement Estimate COPC distributions Discuss decision drivers Write CSM Summary Narrative

25. Step 1d - State the Problem Information INActionsInformation OUT From Previous Step To Next Step Identify COPCs Provide rationale for COPC exclusions Create final list of COPCs with rationale for inclusions Scoping Process Results Scoping Process Issues Global Issues Resolutions Specify release mechanisms Conceptual Site Model Identify fate and transport mechanisms List potential receptors How the release occurred? Still occurring? Single large release? Small release over long time? Stack release of gases? Contaminated debris? Problem Statement Estimate COPC distributions Discuss decision drivers Write CSM Summary Narrative

26. Step 1d - State the Problem Information INActionsInformation OUT From Previous Step To Next Step Identify COPCs Provide rationale for COPC exclusions Begin to evaluate the fate & transport of COPCs Begin to evaluate the distribution of COPCs Create final list of COPCs with rationale for inclusions Scoping Process Results Scoping Process Issues Global Issues Resolutions Specify release mechanisms Conceptual Site Model Identify fate and transport mechanisms List potential receptors Problem Statement Estimate COPC distributions Discuss decision drivers Write CSM Summary Narrative

27. Used 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. Step 1d - State the Problem Information INActionsInformation OUT From Previous Step To Next Step Identify COPCs Provide rationale for COPC exclusions Create final list of COPCs with rationale for inclusions Scoping Process Results Scoping Process Issues Global Issues Resolutions Specify release mechanisms Conceptual Site Model Identify fate and transport mechanisms List potential receptors • Types of sampling media: • Soil • Concrete • Groundwater • Gravel • Etc. Problem Statement Estimate COPC distributions Discuss decision drivers Write CSM Summary Narrative

28. Step 1d - State the Problem Information INActionsInformation OUT From Previous Step To Next Step Identify COPCs Provide rationale for COPC exclusions • Examples of receptors are • Humans • Plants • Animals Create final list of COPCs with rationale for inclusions Scoping Process Results Scoping Process Issues Global Issues Resolutions Specify release mechanisms Conceptual Site Model Identify fate and transport mechanisms List potential receptors Problem Statement Estimate COPC distributions Discuss decision drivers Write CSM Summary Narrative

29. Step 1d - State the Problem Information INActionsInformation OUT From Previous Step To Next Step Identify COPCs Provide rationale for COPC exclusions Create final list of COPCs with rationale for inclusions Scoping Process Results Scoping Process Issues Global Issues Resolutions Specify release mechanisms Conceptual Site Model Spatial and frequency distributions Identify fate and transport mechanisms List potential receptors Problem Statement Estimate COPC distributions This is key point for determining the number of samples Discuss decision drivers Write CSM Summary Narrative

30. Football Field One-Acre 30'0" Football Field

31. Spatial Distribution - Football Field

32. Probability Density Function

33. Frequency Distribution

34. Step 1d - State the Problem Information INActionsInformation OUT From Previous Step To Next Step Identify COPCs Provide rationale for COPC exclusions Create final list of COPCs with rationale for inclusions Liquid spill  Plume model (decreasing with distance) Burn pit  Lateral and vertical heterogeneity Tank sludge  Lateral homogeneity/vertical heterogeneity Fill  What information is available about the fill? Concrete  Drivers? Air; Water; Contact Scoping Process Results Scoping Process Issues Global Issues Resolutions Specify release mechanisms Conceptual Site Model Identify fate and transport mechanisms List potential receptors Problem Statement Estimate COPC distributions Discuss decision drivers Write CSM Summary Narrative

35. % of time when x < m is high, (when n is small) Distribution Curves MoMdMn Mo = Md = Mn Lognormal Normal M0 = mode Md = median Mn = mean

36. Step 1d - State the Problem Information INActionsInformation OUT From Previous Step To Next Step Identify COPCs Provide rationale for COPC exclusions Create final list of COPCs with rationale for inclusions 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) Scoping Process Results Scoping Process Issues Global Issues Resolutions Specify release mechanisms Conceptual Site Model Identify fate and transport mechanisms List potential receptors Problem Statement Estimate COPC distributions Discuss decision drivers Write CSM Summary Narrative

37. Step 1d - State the Problem Information INActionsInformation OUT From Previous Step To Next Step Identify COPCs • Overall 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? Provide rationale for COPC exclusions Create final list of COPCs with rationale for inclusions Scoping Process Results Scoping Process Issues Global Issues Resolutions Specify release mechanisms Conceptual Site Model Identify fate and transport mechanisms List potential receptors Problem Statement Estimate COPC distributions Discuss decision drivers Write CSM Summary Narrative

38. Step 1d - State the Problem Use information gathered from the scoping process, decision maker interviews and the Global Issues Meeting to develop a CSM Information INActionsInformation OUT From Previous Step To Next Step Identify COPCs Provide rationale for COPC exclusions Create final list of COPCs with rationale for inclusions Scoping Process Results Scoping Process Issues Global Issues Resolutions • The CSM may be presented in the following forms: • Narrative statement • Graphical • Tabular Specify release mechanisms Conceptual Site Model Identify fate and transport mechanisms List potential receptors Problem Statement The CSM narrative summary states clearly the current understanding of the condition of the site Estimate COPC distributions Discuss decision drivers Write CSM Summary Narrative

39. CSM Narrative • The Heli-101 Pad and the surrounding soil (surface and underlying) extending laterally up to  95 ft in any direction from the perimeter of the pad and up to a depth of 10 ft constitutes the conceptual model for the contaminated site. It is graphically depicted in the plan view and section view in the following section. Surface soil is defined as soil up to a depth of 6 in. and underlying (subsurface) soil is defined as soil up to a further depth of 10 ft. (Etc.………………………………………..)

40. 0 50 100 150 ft 0 15 30 46 m 0 50 100 150 ft 46 m 0 15 30 Vertical not to scale CSM Spatial Graphical Plan View Former Pad Location Buffer Zone Runoff Zone Section View Former Pad Location Buffer Zone Grade Level Runoff Zone 40 of 101

41. Overview of the Receptor Pathway(CSM) Tabular

42. Step 1d - State the Problem Information INActionsInformation OUT From Previous Step To Next Step Identify COPCs Provide rationale for COPC exclusions Create final list of COPCs with rationale for inclusions Scoping Process Results Scoping Process Issues Global Issues Resolutions Specify release mechanisms Conceptual Site Model Identify fate and transport mechanisms The goal of the DQO Process is to develop a sampling design that will confirm or reject the CSM. List potential receptors Problem Statement Estimate COPC distributions Discuss decision drivers Write CSM Summary Narrative

43. 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

44. Step 1d - State the Problem Information INActionsInformation OUT From Previous Step To Next Step Identify COPCs Provide rationale for COPC exclusions Create final list of COPCs with rationale for inclusions Scoping Process Results Scoping Process Issues Global Issues Resolutions • A concise problem statement describes: • The problem as it is currently understood • The conditions that are causing the problem Specify release mechanisms Conceptual Site Model Identify fate and transport mechanisms List potential receptors Problem Statement Estimate COPC distributions Discuss decision drivers Write CSM Summary Narrative

45. Problem Statement Format • General Format: • In order to[achieve one of the objectives of this study]data regarding[general type of contamination]are needed.

46. Problem Statement Examples • 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.

47. ‘Typical’ Problem Statement Example (YUCK!) • 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.

48. Problem Statement Example In order to [show that lead is contributing to the decrease in duck populations in the wetlands] data regarding [levels of lead in the surface water, sediments, and vegetation in the marshlands] are needed.

49. Step 1 Summary • Comprehensive Scoping is the most important activity • Professional Judgment is the most important skill set • 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 upfront • Performing interviews allows the facilitator to understand each decision maker’s objectives, requirements, and concerns • Resolving global issues allows technical staff to focus on providing defensible designs

50. Step 1 Summary (cont.) • Global issues include land use and interpretation of regulations • 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 Comprehensive Scoping and Professional Judgment • The DQO Process goal is to test the CSM • CSM allows one to focus on problems that are resolved by data/information