1 of 36 The EPA 7-Step DQO Process Step 2 - Identify the Decisions Presenter: Sebastian Tindall 9:30 AM - 9:45 AM (15 minutes) Day 2 DQO Training Course

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The EPA 7-Step DQO Process

Step 2 - Identify the Decisions

Presenter: Sebastian Tindall

9:30 AM - 9:45 AM (15 minutes)

Day 2 DQO Training CourseModule 3

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Terminal Course Objective

To be able to develop principal study questions, alternative actions, assess potential errors and their consequences and the severity of the consequence of the error

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Step Objective:

Develop decision statements that require environmental data to address the objective of the problem statement

Step 2: Identify Decisions

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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Information IN Actions Information OUT

From Previous Step To Next Step

Decision Statements

Concise Statement of the

Problem

Identify Principal Study Questions

Define Alternative Actions

Step 2- Identify Decisions

Define Error if AA Incorrectly Taken

List Consequences of Errors

Rate Severity of Consequences

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Background

Principal Study Question: PSQ

Alternative Action: AAThe PSQ identifies key unknown conditions or unresolved issues that reveal the solution to the Problem.

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Background


Alternative Action: AAGenerally, all PSQs require data via environmental measurements (old or new) to be resolved.

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Background


Alternative Action: AA

All the possible actions that might be taken once a PSQ has been resolved.

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Creating a Decision Statement

PSQPSQ + AAAA

Decision Decision StatementStatement

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What types of Decisions Require the DQO Process?

Only decisions whose PSQs require data (environmental measurements) to resolve

Three general types of decisions:

d: Red shovel/green shovel decisions

D: Decisions requiring environmental data

D: Large programmatic decisions

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TEST: Does the PSQ require data via environmental measurements (old or new) to be resolved?

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Examples of technical decisions made by experts based on professional knowledge, and that require no analytical data: • What PPE is required? • Should we use a split spoon or a Shelby tube?

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Is this project regulated under the Resource Conservationand Recovery Act of 1976 (RCRA) orthe Comprehensive Environmental Response,Compensation, and Liability Act of 1980 (CERCLA) project? (This is legal or regulatory decision,no data needed.)

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Do we need to collect data via environmental measurements to decide whether or not the decrease in duck population is due to the leadpellets in the wetlands?

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Decision Statements


Problem







Identify the questions that mustbe addressed in order to resolvethe problem statement. Note that it is useful to divide these by either the matrix to be studied, the type waste, etc.

Addressing the question will resolve the problem.

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Example PSQs

Is the Smith property radiologically contaminated?

Does the waste exceed toxicity characteristic (TC) criteria?

Is the waste ignitable?

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PSQs

1. Are the perimeter side slope soils contaminated?

2. Are the trench footprint soils below 20 ft contaminated?

CS

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Decision Statements


Problem







For each question, list the actions that may be taken as a result of answering the question.These actions use verbs such as “remove, dispose, delist.”

Decision rules (DRs) will be written in Step 5 to provide the criteria to select between the AAs. After data collection, DRs are used to select the appropriate AA.

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Example RelationshipBetween PSQs and AAs

PSQ#

PSQ AA# AAa

1 Yes – Remediate the contaminated soil1

Is the Smith property radiologicallycontaminated? 2 No – No further action needed

1Yes – Dispose in permitted landfill forRCRA and consider underlyinghazardous constituents (UHCs)2 Does the waste exceed TC criteria?

2No – Consider all other RCRAcharacteristics

1Yes – Dispose in RCRA permittedlandfill

3 Is the waste ignitable?2

No – Consider all other RCRAcharacteristics

aAn AA contains an action verb such as “rubblize,” “remove,” or “dispose.”

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PSQ#

PSQ AA# AAa

1 Yes – Conduct remedial action1

Are the perimeter side slope soilscontaminated? 2 No – no further action required

1 Yes – Conduct remedial action2

Are the trench footprint soils below20 ft contaminated? 2 No – no further action required

aAn AA contains an action verb such as “rubblize,” “remove,” or “dispose.”

CSRelationship BetweenPSQs and AAs

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Decision Statements


Problem







Identify qualitative descriptions of the potential errors that could occur

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Decision Statements


Problem







List the consequences of eachqualitative error listed for eachPSQ and AA.

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Decision Statements


Problem







Perform a qualitative and relative assessment of the consequences of taking each AA.

Express in terms of:• Low• Moderate• Severe

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Decision Statements


Problem







When assessing consequences, take the following aspects into consideration:• Human health• Environment (flora/fauna) • Political• Economic• Legal

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Errors, Consequences and SeverityConsequences of Incorrectly Taking Each Alternative Action

PSQ#

AA#

Alternative ActionError if AA

Incorrectly TakenConsequences of

ErrorSeverity of

Consequences

1Designate for TCand performevaluation of UHCs.

Inappropriate wastedesignation anddisposal to regulatedlandfill.

Financial impacts dueto disposal path,additional analysisfor UHCs.

Moderate

2

2

Waste determined tonot exceed TC,evaluated for otherRCRAcharacteristics.

Incorrect designationresults in improperwaste disposal.

Potential risk tohuman health and theenvironment.

Moderate -Severe

1Waste is determineto be ignitable.

Inappropriate wastedesignation anddisposal to regulatedlandfill.

Financial impacts dueto disposal path.

Moderate

3

2Waste determinednot to be ignitable.

Incorrect designationresults in improperwaste disposal.

Potential risk tohuman health and theenvironment.

Moderate -Severe

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Consequences of Incorrectly Taking Each Alternative Action

PSQ#

AA#

Alternative ActionError if AA

Incorrectly TakenConsequences of

ErrorSeverity of

Consequences

1Conduct remedialaction

Clean site undergoesremedial action

Financial impacts tothe budget

Normal constructionhazards providepotential for workersafety issues.

Moderate

1,2

2No further actionrequired

Contaminated site leftunabated.

Potential risk tohuman health andenvironment

Severe

Errors, Consequences, and SeverityCS

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Decision Statements


Problem







Decision statements link alternative actions with PSQs.

Step 5 will provide criteria toselect between alternatives.

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Decision Statements


Problem







Decision statements express a choice between AAs.

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Decision Statements General Format:

Determine whether [Principal Study Question #1] requires [Alternative Action A] or [Alternative Action B].

Added Clarification:

Determine whether [unknown environmental condition/issue/criterion from the Problem Statement] requires [choosing between two or more Alternative Actions].

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General Format:

Determine whether [Principal Study Question #1] requires [Alternative Action A] or [Alternative Action B].

Added Clarification:

Determine whether [unknown environmental condition/issue/criterion from the Problem Statement] requires [choosing between two or more Alternative Actions].

Using a standardized format is important because it helps: • Eliminate red/green shovel PSQs • Improve the consistency between

DQO documents • Make it easier for the reviewer to

understand the decisions to be made

Decision Statements

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Decision Statement Example

EXAMPLE:

Determine whether [the waste contains TC constituents that exceed regulatory criteria] and requires [an evaluation of the underlying hazardous constituents] or [does not exceed TC criteria and requires consideration only of other RCRA characteristics].

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EXAMPLE:

Determine whether [the waste is ignitable] and requires [disposal in a RCRA landfill] or [requires only consideration of the remaining RCRA characteristics].

Decision Statement Example

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‘Typical’ Decision Statement Examples

EXAMPLE:

The question is whether [a cap is needed and what COPCs are needed to assess the effectiveness of the cap].

EXAMPLE:

Lard oil that contained carbon tetrachloride was used; however it is unclear as to whether [the oil nad carbon tetrachloride are listed waste].

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Decision Statements

1. Determine whether the perimeter side slope soils are contaminated and require remedial action or require no further action.

2. Determine whether the trench footprint soils below 20 ft are contaminated and require remedial action or require no further action.

CS

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Step 2 Summary

Decisions that are regulatory or professional judgement are not part of the Step 2 decisions

For the decision to be valid, there must be two or more alternative actions

Data are needed to choose between the alternative actions

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Decision Statements


Problem







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End of Module 3

Thank you

Documents

1 of 36 The EPA 7-Step DQO Process Step 2 - Identify the Decisions Presenter: Sebastian Tindall 9:30 AM - 9:45 AM (15 minutes) Day 2 DQO Training Course