1 of 40 The EPA 7-Step DQO Process Step 2 - Identify the Decisions Presenter: Sebastian Tindall (30 minutes) DQO Training Course Day 2 Module 12

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The EPA 7-Step DQO Process

Step 2 - Identify the Decisions

Presenter: Sebastian Tindall

(30 minutes)

DQO Training CourseDay 2

Module 12

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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 AAs Incorrectly Taken

List Consequences of Errors

Rate Severity of Consequences

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Background

Principal Study Question: PSQ

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

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Background

Principal Study Question: PSQ

Alternative Actions: AAs

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

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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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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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Examples of PSQs:Soil Remediation

PSQ#

Principal Study Question

1Do the residual soil radionuclide concentrations in the waste site(s) exceed theannual radiological exposure limits for human health or groundwater protection?

2Do the residual soil concentrations of nonradiological constituents in the wastesite(s) exceed the nonradiological exposure limits for human health orgroundwater protection?

3Do the residual soil radionuclide concentrations in the soils remaining in the wastesite(s) exceed the annual radiological occupational exposure limits for theremediation workers?

4Do the residual soil concentrations of nonradiological constituents in the wastesite(s) exceed the nonradiological occupational exposure limits for the remediationworkers?

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Examples of PSQs:Decontamination & Decommissioning

PSQ#


1aDoes the radiological activity in the soils underlying the FSB floor exceed theradiological DCGLs?

1bDo the chemical COC concentrations in the soils underlying the FSB floor exceedthe chemical release cleanup levels?

2aDoes the radiological activity in the FSB concrete exceed the shallow and deepzone radiological DCGLs?

2bDo the chemical COC concentrations in the FSB concrete exceed the shallow anddeep zone chemical release cleanup levels?

3aDoes the radiological activity in the shallow zone BGRT concrete exceed theshallow zone radiological DCGLs?

3bDo the chemical COC concentrations in the shallow zone BGRT concrete exceedthe shallow zone chemical release cleanup levels?

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Examples of PSQs:Decontamination & Decommissioning (cont)

PSQ#


4aDoes the radiological activity in the deep zone BGRT areas exceed the deep zoneradiological DCGLs?

4bDo the chemical COC concentrations in the deep zone BGRT areas exceed thedeep zone chemical release cleanup levels?

5aDoes the radiological activity in the drain pipe bedding soils under concrete slabsor adjacent soils exceed the shallow or deep zone radiological DCGLs?

5bDo the specific chemical concentrations in the drain pipe bedding soils underconcrete slabs or adjacent soils exceed the shallow or deep zone chemical releasecleanup levels for that constituent?

BGRT = Below grade rooms and tunnelsDCGL = Derived concentration guideline limit

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Examples of PSQs:RI/FS

PSQ#


1Do the contaminant concentrations in the OU representative waste sites exceedthe TRU or the Greater than Class C waste definition?

2Do the radionuclide concentrations in OU representative waste sites exceed theannual radiological exposure limits for human health or groundwater protection?

3Do the concentrations of nonradiological constituents in the OU representativewaste sites exceed the nonradiological exposure limits for human health orgroundwater protection?

4Do the OU conceptual contaminant distribution models properly reflect thephysical characteristics and distribution of contaminants in the waste sites?

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Examples of PSQs:Waste Designation

PSQ#


1Does the waste material radiological activity exceed the disposal facility wasteacceptance criteria limits?

2Do the waste material chemical and/or physical properties exceed the disposalfacility waste acceptance criteria limits?

3 Is the waste material a dangerousa, PCB, or asbestos waste?

3a Is the waste material a listed dangerous waste?

3bIs the waste material a characteristic dangerous waste (e.g., ignitable, corrosive,reactive, or toxic)?

3c Is the waste material a toxic dangerous waste per Washington State criteria?

3d Is the waste material a persistent dangerous waste per Washington State Criteria?

3e Is the waste material a PCB waste?

3f Is the waste material ACM?

4b Is the waste material land disposal restricted?a The definition of dangerous waste also includes hazardous waste/b There is no PSQ that considers treated waste, because that would be the subject of a post-treatment

characterization activity.

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Examples of PSQs:New Waste Designation

PSQ#


1Does CERCLA well decommissioning volumetric material exceed ERDFradiological waste acceptance criteria?

2Does RCRA well decommissioning volumetric material have a radiologicalcomposition that requires disposal in the Low-Level Burial Ground?

3 Is the material a listed dangerous waste?

3b Is the material a characteristic waste (e.g., ignitable, corrosive, reactive, or toxic)?

3c Is the material a toxic dangerous waste as defined by Washington State criteria?

3d Is the material a persistent waste as defined by Washington State criteria?

3e Is the material a PCB waste?

3f Is the material an asbestos waste

4 Is the material land disposal restricted?

5Does the land disposal restricted (treated) material meet UTS and disposal facilitywaste acceptance criteria limits?

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Examples of PSQs:River Protection Project

PSQ#


1Will the wastes remaining at the time of closure meet the characteristicrequirements required by regulations?

2Are the inventories and release rates of key radionuclides (e.g., Tc, I, U isotopes)below the limits needed to protect long-term public health and the groundwaterresource?

3Are the inventories and release rates of key chemicals (e.g., NO3, Cr6+, U, Na)below the limits needed to protect long-term public health and the groundwaterresource?

4Are the concentrations of key radionuclides (e.g., 241 Am, 239,240Pu) below thelimits to protect the inadvertent intruder?

5 Are the concentrations of radionuclides below Class C limits or its equivalent?

6Are the concentrations (and amounts ?) of chemicals meet the requirements of theRCRA Part A permit?

7Are the concentrations (and amounts ?) of chemicals below the Land DisposalRequirement or its equivalent?

8Are the concentrations and amounts of contaminants below the levels implied bythe risk assignment prepared according to MTCA?

PSQs

1. Are the site surface soils contaminated?

2. Are the underlying soils 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 AAs.

AAs

1. Conduct remedial action (TBD).

2. No further action required.

CS

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Creating a Decision Statement

PSQPSQ + AAsAAs

Decision Decision StatementStatement

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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.”

CSRelationship BetweenPSQs and AAs

PSQ#

Principal Study Question (PSQ) AA# Alternative Action (AAa)

1 Yes – Conduct remedial action1

Are the site surface soilscontaminated? 2 No – no further action required

1 Yes – Conduct remedial action2

Are the underlying soilscontaminated? 2 No – no further action required

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

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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 AAs.

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Decision Statements


Problem







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

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

Errors, Consequences and SeverityCS

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

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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].

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General Format:

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

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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‘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 and carbon tetrachloride are listed wastes.

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Decision Statement Example

EXAMPLE:

Determine whether [the surface soil of the Smith property is radiologically contaminated] and requires [disposal in a radiological landfill]; if not [requires no action].

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Decision Statement Example

EXAMPLE:

Determine whether [lead is contributing to the decrease in duck populations] and requires [remediation by removal of the lead from the bottom of the ponds]; if not [regulation on the types of pellets that future hunters may use]; if not [requires no action].

Decision Statements

1. Determine whether the surface soils are contaminated and require remedial action; if not require no further action.

2. Determine whether the site underlying soils are contaminated and require remedial action; if not 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 12

Thank you

Questions?

Documents

1 of 40 The EPA 7-Step DQO Process Step 2 - Identify the Decisions Presenter: Sebastian Tindall (30 minutes) DQO Training Course Day 2 Module 12