The EPA 7-Step DQO Process

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The EPA 7-Step DQO Process

Step 1 - State the Problem

Presenter: Sebastian Tindall

60 minutes

DQO Training CourseDay 2

Module 9

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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)

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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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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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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

Step 1a - 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

Step 1b - State the Problem

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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

Scoping Process Results

Scoping Process Issues

Step 1c - State the Problem



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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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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


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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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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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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


Have the ultimate authority for making final decisions basedon the recommendations of the DQO Team:• Federal Facility• Environmental Protection Agency• State Regulatory Agency


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Continue activities



Planning Meeting


Decision Makers:• Seek, consider, and represent the concerns of the Stakeholders


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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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•Objectives


•Concerns





Continue activities

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


Note

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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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What are the decision drivers:(risk? regulatory limits? etc.)

What is distribution of COPCs at site?



How has fate & transport affected site?

What are the COPCs?

Develop Conceptual Site

Model

Concise Statement of the Problem

How did COPCs arrive at site?


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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 Sr-90, Cs-137, etc.


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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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Identify COPCs

Identify the Final List of COPCs


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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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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.

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

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Identify COPCs

Examples of receptors are • Humans• Plants• Animals


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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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Frequency DistributionConcentration,

pCi/gNumber of occurances

1 02 03 94 785 2696 3737 2258 439 3

10 0

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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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Mo = Md = Mn

Normal

Mo Md Mn

Lognormal

M0 = modeMd = medianMn = mean

% of time when x < is high,(when n is small)

Distribution Curves

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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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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


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

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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.………………………………………..)

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Plan View

Section View

Former PadLocation

RunoffZone

0 50 100 150 ft0 15 30 46 m

Former PadLocation

RunoffZone

Grade Level

0 50 100 150 ft0 15 30 46 m

Vertical not to scale

BufferZone

CSM Spatial Graphical

BufferZone

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Overview of the Receptor Pathway(CSM) Tabular

PrimarySources

PrimaryRelease

Mechanism

SecondarySources

SecondaryRelease

MechanismPathway

Oil andFuel

Residualfrom

Equipment

Spills

Cleaning

Soil

Dust

StormWaterRunoff

Wind

SurfaceWater &

Sediments

ReceptorHuman Biota

Exposure Route A

rea

Res

iden

tsS

i te

visi

tors

Terr

estr

ial

Aqu

atic

IngestionInhalation X X XDermal Contact

Ingestion X X XDermal Contact X X X

Ingestion X X X XInhalationDermal Contact X X X X

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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 [achieve one of the objectives of

this study] data regarding [general type of contamination] are needed.

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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

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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 (YUCK!)

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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.

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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

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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

Step 1 Summary (cont.)

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Continue activities



Planning Meeting



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Continue activities











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•Objectives


•Concerns








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Identify COPCs


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End of Module 9

Thank you

Questions?

Documents

The EPA 7-Step DQO Process