Michael W. Cline Date: 2021.04.22 09:05:35 -07'00

Richland Operations Office P.O. Box 550 Richland, Washington 99352

Office of River Protection P.O. Box 450 Richland, Washington 99352

U.S. Department of Energy Hanford Site

21-SGD-001408 April 22, 2021 Ms. Emerald Laija, Program Manager U.S. Environmental Protection Agency 1200 Pennsylvania Ave., NW MC 5106R Washington, District of Columbia 20460 Dear Ms. Laija: 200-ZP-1 OPERABLE UNIT OPTIMIZATION STUDY SAMPLING AND ANALYSIS PLAN This letter transmits the approved 200-ZP-1 Operable Unit Optimization Study Sampling and Analysis Plan DOE/RL-2019-76, Revision 0 and the Review Comment Record to the U.S. Environmental Protection Agency (EPA). This document incorporates EPA's comments and outlines the sampling needed to support the 200-ZP-1 Operable Unit Optimization Study Plan. If there are any questions, please contact me or your staff may contact Kate Amrhein, of my staff, on (509) 376-9391. Sincerely, Michael W. Cline, Director

Soil and Groundwater Division Richland Operations Office

SGD:KEA Attachments: 1. DOE/RL-2019-76, R0 2. DOE/RL-2019-76, R0, Comment Record cc: See page 2

Michael W. Cline Digitally signed by Michael W. Cline Date: 2021.04.22 09:05:35 -07'00'

Ms. Emerald Laija: -2- 21-SGD-001408 cc w/ attach: J. Bell, NPT D. B. Bowen, Ecology R. Buck, Wanapum L. Contreras, YN D. R. Einan, EPA S. Leckband, HAB N. M. Menard, Ecology M. Murphy, CTUIR S. N. Schleif, Ecology M. Woods, ODOE

April 22, 2021

Administrative Record (200-ZP-1) Environmental Portal

cc w/o attach: S. G. Austin, CPCCo S. L. Brasher, HMIS M. E. Byrnes, CPCCo S. W. Davis, HMIS R. E. Fox, CPCCo

DOE/RL-2019-76Revision 0

200-ZP-1 OPERABLE UNIT OPTIMIZATION STUDYSAMPLING AND ANALYSIS PLAN

Prepared for the U.S. Department of EnergyAssistant Secretary for Environmental Management

P.O. Box 550 Richland, Washington 99352

Approved for Public Release; Further Dissemination Unlimited


200-ZP-1 OPERABLE UNIT OPTIMIZATION STUDY SAMPLINGAND ANALYSIS PLAN

Date PublishedJanuary 2021

Prepared for the U.S. Department of Energy Assistant Secretary for Environmental Management

P.O. Box 550 Richland, Washington 99352

Release Approval Date

By Janis D. Aardal at 9:19 am, Jan 12, 2021

Approved for Public Release; Further Dissemination Unlimited


TRADEMARK DISCLAIMER Reference herein to any specific commercial product, process, or service bytradename, trademark, manufacturer, or otherwise, does not necessarilyconstitute or imply its endorsement, recommendation, or favoring by theUnited States Government or any agency thereof or its contractors orsubcontractors.

This report has been reproduced from the best available copy.

Printed in the United States of America

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Signature Page

Title: 200-ZP-1 Operable Unit Optimization Study Sampling and Analysis Plan

Concurrence:

________________________________ ___________________________________ __________

Print Name Signature Date

U.S. Department of Energy, Richland Operations Office

________________________________ ___________________________________ __________

Print Name Signature Date

U.S. Environmental Protection Agency

Michael W. Cline Digitally signed by Michael W. Cline Date: 2021.01.19 15:47:02 -08'00'

EMERALD LAIJA Digitally signed by EMERALD LAIJA Date: 2021.01.21 09:38:42 -05'00'

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Contents

1 Introduction .................................................................................................................................... 1-1

1.1 Project Scope and Objective ................................................................................................... 1-4

1.1.1 Remedy Implementation Documentation ................................................................... 1-6

1.1.2 Scope ................................................................................................................... 1-7

1.1.3 Objectives ................................................................................................................... 1-9

1.2 Background ............................................................................................................................ 1-9

1.2.1 Site Geology/Hydrology ........................................................................................... 1-11

1.2.2 Groundwater Flow .................................................................................................... 1-11

1.2.3 Sources of Contamination ......................................................................................... 1-11

1.2.4 Contaminant Plumes ................................................................................................. 1-12

1.3 Data Quality Objective Summary ........................................................................................ 1-17

1.3.1 Statement of the Problem .......................................................................................... 1-17

1.3.2 Project Task and Problem Definition ........................................................................ 1-17

1.3.3 Decision Statements and Decision Rules .................................................................. 1-18

1.3.4 Data Inputs and Sampling Design ............................................................................. 1-22

1.4 Target Analytes .................................................................................................................... 1-25

1.5 Project Schedule ................................................................................................................... 1-26

2 Quality Assurance Project Plan .................................................................................................... 2-1

2.1 Project Management ............................................................................................................... 2-1

2.1.1 Project/Task Organization ........................................................................................... 2-1

2.1.2 Quality Objectives and Criteria ................................................................................... 2-5

2.1.3 Methods-Based Analysis ............................................................................................ 2-5

2.1.4 Special Training/Certification ..................................................................................... 2-9

2.1.5 Documents and Records ............................................................................................. 2-9

2.2 Data Generation and Acquisition ......................................................................................... 2-11

2.2.1 Analytical Methods Requirements ............................................................................ 2-12

2.2.2 Field Analytical Methods .......................................................................................... 2-13

2.2.3 Quality Control ......................................................................................................... 2-13

2.2.4 Measurement Equipment .......................................................................................... 2-18

2.2.5 Instrument and Equipment Testing, Inspection, and Maintenance ........................... 2-18

2.2.6 Instrument/Equipment Calibration and Frequency ................................................... 2-19

2.2.7 Inspection/Acceptance of Supplies and Consumables .............................................. 2-19

2.2.8 Nondirect Measurements .......................................................................................... 2-19

2.2.9 Data Management ..................................................................................................... 2-19

2.3 Assessment and Oversight .................................................................................................... 2-19

2.3.1 Assessments and Response Actions .......................................................................... 2-19

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2.3.2 Reports to Management ............................................................................................ 2-20

2.4 Data Review and Usability ................................................................................................... 2-20

2.4.1 Data Review and Verification ................................................................................... 2-20

2.4.2 Data Validation ......................................................................................................... 2-20

2.4.3 Reconciliation with User Requirements ................................................................... 2-21

3 Field Sampling Plan ....................................................................................................................... 3-1

3.1 Sampling Objectives/Design .................................................................................................. 3-1

3.2 Sample Locations and Frequency ........................................................................................... 3-1

3.3 Sampling Methods .................................................................................................................. 3-5

3.3.1 Decontamination of Sampling Equipment .................................................................. 3-6

3.3.2 Radiological Field Data .............................................................................................. 3-7

3.3.3 Water Levels ............................................................................................................... 3-8

3.4 Documentation of Field Activities ......................................................................................... 3-8

3.4.1 Corrective Actions and Deviations for Sampling Activities ....................................... 3-9

3.5 Calibration of Field Equipment .............................................................................................. 3-9

3.6 Sample Handling .................................................................................................................. 3-10

3.6.1 Containers ................................................................................................................. 3-10

3.6.2 Container Labeling .................................................................................................... 3-11

3.6.3 Sample Custody ........................................................................................................ 3-11

3.6.4 Sample Transportation .............................................................................................. 3-12

4 Management of Waste ................................................................................................................... 4-1

5 Health and Safety ........................................................................................................................... 5-1

6 Reporting ........................................................................................................................................ 6-1

7 References ....................................................................................................................................... 7-1

Appendix

A Data Quality Objectives for the 200-ZP-1 Operable Unit Optimization Study ........................ A-i

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Figures

Figure 1-1. Location of the Hanford Site and the 200-ZP-1 OU ............................................................ 1-2

Figure 1-2. 200-ZP-1 OU Optimization Study Long-Term Groundwater Monitoring Network ........... 1-5

Figure 1-3. 200-ZP-1 OU Remedy Implementation and Reporting ....................................................... 1-8

Figure 1-4. Two-Dimensional Model Prediction of 200-ZP-1 OU Carbon Tetrachloride Plume ........ 1-13

Figure 1-5. Hydrogeologic Three-Dimensional Model Cross Section of Carbon

Tetrachloride Plume, North to South (A to A′) .................................................................. 1-15

Figure 1-6. Hydrogeologic Three-Dimensional Model Cross Section of Carbon

Tetrachloride Plume, West to East (B to B′) ...................................................................... 1-16

Figure 2-1. Project Organization ............................................................................................................ 2-2

Tables

Table 1-1. Principal Study Questions .................................................................................................. 1-18

Table 1-2. Decision Statements ........................................................................................................... 1-19

Table 1-3. Decision Rules ................................................................................................................... 1-20

Table 1-4. Summary of Data Inputs to Resolve DSs .......................................................................... 1-21

Table 1-5. 200-ZP-1 OU Optimization Study Long-Term Monitoring Well Network ....................... 1-23

Table 1-6. Analytes for 200-ZP-1 OU Optimization Study Long-Term Groundwater Monitoring .... 1-26

Table 2-1. Data Quality Indicators ........................................................................................................ 2-6

Table 2-2. Change Control for Sampling Projects ................................................................................ 2-9

Table 2-3. Performance Requirements for Sample Analysis .............................................................. 2-12

Table 2-4. QC Samples ....................................................................................................................... 2-13

Table 2-5. Field and Laboratory QC Elements and Acceptance Criteria ............................................ 2-14

Table 2-6. Holding-Time Guidelines for Laboratory Analytes ........................................................... 2-18

Table 3-1. 200-ZP-1 OU Optimization Study Long-Term Groundwater Monitoring Schedule ........... 3-1

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Terms

AEA Atomic Energy Act of 1954

CERCLA Comprehensive Environmental Response, Compensation, and Liability

Act of 1980

COC contaminant of concern

COPC contaminants of potential concern

DOE U.S. Department of Energy

DOE-RL U.S. Department of Energy, Richland Operations Office

DOT U.S. Department of Transportation

DQI data quality indicator

DQO data quality objective

DR decision rule

DS decision statement

DUA data usability assessment

DUP laboratory sample duplicate

EB equipment blank

Ecology Washington State Department of Ecology

EPA U.S. Environmental Protection Agency

F&T fate and transport

FS feasibility study

FSO Field Sample Operations

FTB full trip blank

FWS field work supervisor

FXR field transfer blank

FY fiscal year

HASQARD Hanford Analytical Services Quality Assurance Requirements Document

HEIS Hanford Environmental Information System

IATA International Air Transportation Association

LCS laboratory control sample

MB method blank

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MNA monitored natural attenuation

MS matrix spike

MSD matrix spike duplicate

NTU nephelometric turbidity unit

O&M operations and maintenance

OSP optimization study plan

OU operable unit

P&T pump and treat

P2R Model Plateau to River Model

PMP performance monitoring plan

PSQ principal study question

QA quality assurance

QAPjP quality assurance project plan

QC quality control

QSM Quality Systems Manual

RAO remedial action objective

RCRA Resource Conservation and Recovery Act of 1976

RCT radiological control technician

RD/RAWP remedial design/remedial action work plan

Rlm Ringold Formation member of Wooded Island – lower mud unit

ROD Record of Decision

Rwia Ringold Formation member of Wooded Island – unit A

Rwie Ringold Formation member of Wooded Island – unit E

S&GRP Soil and Groundwater Remediation Project

SAP sampling and analysis plan

SMR Sample Management and Reporting

SPLIT field split sample

SUR surrogate

TCE trichloroethene

Tri-Party Agreement Hanford Federal Facility Agreement and Consent Order

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1 Introduction

A focused optimization study is currently underway that is designed to evaluate changes to the current

pump and treat (P&T) configuration for the 200-ZP-1 Groundwater Operable Unit (OU) to increase

carbon tetrachloride treatment capacity. Figure 1-1 depicts the location of the Hanford Site and the

200-ZP-1 OU. The optimization study requirements are documented in DOE/RL-2019-38, 200-ZP-1

Operable Unit Optimization Study Plan (hereinafter referred to as the 200-ZP-1 OU optimization study

plan [OSP]). The optimization study is being conducted in conjunction with the activities identified in

DOE/RL-2008-78, Rev. 1, 200 West Area 200-ZP-1 Pump-and-Treat Remedial Design/Remedial Action

Work Plan (hereinafter referred to as the 200-ZP1 P&T remedial design/remedial action -work plan

[RD/RAWP]). The 200-ZP-1 OU OSP documents a remedial optimization approach designed to

increase carbon tetrachloride removal from within the Ringold Formation member of Wooded Island –

unit E (Rwie) and ultimately accelerate progress toward attaining groundwater cleanup goals.

The 200-ZP-1 OU optimization study groundwater monitoring has been divided into two phases:

near-term (first year of the study) and long-term (second year through the duration of the study). This

sampling and analysis plan (SAP) presents the 200-ZP-1 OU optimization study long-term groundwater

monitoring requirements.

Groundwater remediation at the 200-ZP-1 OU is currently in progress in accordance with

EPA et al., 2008, Record of Decision Hanford 200 Area 200-ZP-1 Superfund Site, Benton County,

Washington (hereinafter referred to as the 200-ZP-1 OU Record of Decision [ROD]). The groundwater

remedy detailed in the 200-ZP-1 OU ROD is comprised of P&T, flow-path control, and institutional

controls, followed by monitored natural attenuation (MNA). The ROD estimates that remediation will

require 125 years to achieve final cleanup levels for eight contaminants of concern (COCs), with carbon

tetrachloride being the primary risk driver and with a high concentration relative to the cleanup level and

corresponding large mass within the aquifer. The remedy is designed so P&T and MNA will occur

concurrently during the 25-year period of active P&T to reduce contaminant concentrations, and then

MNA will further reduce concentrations over the following 100 years to final cleanup levels.

Operations began at the 200 West P&T in July 2012, and remedy performance has been evaluated

annually since that time. The results of the evaluations are documented in annual 200 West Area P&T

reports (e.g., DOE/RL-2019-68, Calendar Year 2019 Annual Summary Report for Pump and Treat

Operations in the Hanford Site Central Plateau Operable Units). The evaluations have demonstrated that

system-wide flow rates, plume hydraulic containment, and mass recovery rates are following the targets

established in the 200-ZP-1 P&T RD/RAWP (DOE/RL-2008-78, Rev. 0 REISSUE). However,

assessment of 200-ZP-1 OU remedy performance for the first 6 years of implementation has indicated

that the P&T configuration needs to be modified to increase the capacity for carbon tetrachloride

remediation. Data and information obtained following issuance of the 200-ZP-1 OU ROD

(EPA et al., 2008) suggest that conditions are less favorable for attaining the carbon tetrachloride cleanup

level with the current P&T configuration in the timeframe specified in the ROD.

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Figure 1-1. Location of the Hanford Site and the 200-ZP-1 OU

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Multiple factors impact remedy performance, and additional and more frequent data collection and

additional information are needed to optimize the P&T remedy and support potential modifications of the

associated remedy decision documents. Among the factors impacting remedy performance are:

The slower-than-anticipated degradation rate for carbon tetrachloride (630 years versus the 41.3-year

half-life used in Rev. 0 of the 200-ZP-1 P&T RD/RAWP [DOE/RL-2008-78]), which greatly reduced

the contribution of abiotic degradation to carbon tetrachloride natural attenuation and necessitates

greater P&T operating rates and/or longer duration to reduce concentrations to the point that MNA

can achieve cleanup levels in the timeframe specified in the 200-ZP-1 OU ROD (EPA et al., 2008).

A larger mass of carbon tetrachloride is present in the Rwie than was presented in DOE/RL-2007-28,

Feasibility Study Report for the 200-ZP-1 Groundwater Operable Unit (hereinafter referred to as the

200-ZP-1 OU feasibility study [FS]).

Most nitrate in groundwater is currently present at concentrations that are less than an order of

magnitude above the cleanup level. Considering current nitrate concentration trends and assuming

there is no continuing source of nitrate, sufficient nitrate may have already been removed from the

aquifer (resulting in substantial concentration reductions) to enable a transition to the MNA phase of

the remedy that will still allow the nitrate cleanup level to be reached within the timeframe specified

in the 200-ZP-1 OU ROD (EPA et al., 2008).

Optimization of the 200-ZP-1 OU P&T remedy performance is needed to accelerate carbon tetrachloride

mass removal and increase treatment capacity to levels that are expected to approach the

required cleanup criteria.

Regulatory approval was obtained to implement the 200-ZP-1 OU OSP (DOE/RL-2019-38) on

September 30, 2019. The purpose of the optimization study is to collect and interpret data to evaluate

remedy performance enhancements through P&T configuration changes associated with 200 West P&T

operations. It is intended that the results from the study will provide the technical basis for

recommendations regarding whether to formally modify the P&T configuration and the associated

remedy decision documents.

The 200-ZP-1 OU OSP (DOE/RL-2019-38) emphasizes configuration changes and data collection for

the Rwie and provides the basis and approach for conducting the optimization study to meet the needs

detailed in the 200-ZP-1 P&T RD/RAWP (DOE/RL-2008-78, Rev. 1). The purpose of the optimization

study is to collect and interpret data to evaluate remedy performance enhancements and P&T

configuration changes associated with P&T operations. The data quality objective (DQO) process was

used to determine and document the data and information to be collected and evaluated in order to meet

the optimization study objectives. Appendix A presents the DQOs for the OSP. This focused SAP was

developed to specify the data that will be collected to support the 200-ZP-1 OU OSP long-term

groundwater monitoring requirements.

The optimization study focuses on the Rwie and is anticipated to have minimal impact on contamination

in the Ringold Formation member of Wooded Island – unit A (Rwia), except (1) in areas where the

intervening low-conductivity Ringold Formation lower mud unit (Rlm) is absent so the unconfined

aquifer is continuous within the Rwie and Rwia, and (2) where some of the extraction and injection wells

are screened within both the Rwie and Rwia. A separate investigation is being performed to more fully

evaluate and understand the nature and extent of contamination in the Rwia, which will then be used to

determine the treatment needs for that unit. Activities to be performed as part of the Rwia investigation

are detailed in DOE/RL-2019-23, 200-ZP-1 Operable Unit Ringold Formation A Characterization

Sampling and Analysis Plan (hereinafter referred to as the Ringold A SAP).

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The 200-ZP-1 OU OSP (DOE/RL-2019-38) was approved on September 30, 2019, providing the

regulatory approval to begin the optimization study. The optimization study groundwater monitoring

requirements have been divided into two phases: near-term and long-term. The duration of the near-term

200-ZP-1 OU optimization study groundwater monitoring is defined as the one-year period following

suspension of the active biological treatment, which occurred on October 9, 2019 (i.e., fiscal year

[FY] 2020). The near-term groundwater sampling and analysis requirements were implemented through

TPA-CN-0875, TPA Change Notice Form, DOE/RL-2009-115, Performance Monitoring Plan for the

200-ZP-1 Operable Unit Remedial Action, Revision 2, and are not included in this SAP.

The duration of long-term groundwater monitoring for the 200-ZP-1 OU optimization study is defined as

starting after the end of the near-term monitoring and continuing through the duration of the optimization

study (i.e., FY 2021 through FY 2024, with the possibility of extending through FY 2026). The sampling

and analytical requirements for the optimization study long-term groundwater monitoring are documented

in this SAP. Figure 1-2 depicts the 200-ZP-1 OU optimization study long-term groundwater monitoring

well network. Each new well (e.g., Resource Conservation and Recovery Act of 1976 [RCRA], the

Atomic Energy Act of 1954 [AEA], and 200-UP-1 OU) installed in proximity to the 200-ZP-1 OU carbon

tetrachloride plume during the optimization study timeframe will be evaluated for inclusion in the study.

Section 1.3.4 discusses the steps to be used in the well selection process.

A comprehensive evaluation was initiated in FY 2020 (and continues into FY 2021) as a separate activity

taking place concurrently with the optimization study to provide a technical assessment of near- and

long-term projected plume remediation, COC treatment, and source contaminant requirements for other

COCs and contaminants of potential concern (COPCs). The resulting recommendations from this effort

will develop the basis for additional remedy optimization actions that will be integrated into necessary

Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) decision

documents and remedy optimization efforts (anticipated to occur in the FY 2021/2022 timeframe) for

relevant OUs in the Central Plateau, including 200-ZP-1. An initial summary of these activities is

presented in SGW-65172-VA, 200-ZP-1 Optimization Study – Resolution of RL Comments Regarding

Integration of a Comprehensive Remediation Evaluation of Groundwater Plumes and Well Networks.

1.1 Project Scope and Objective

Performance assessment of the 200-ZP-1 OU remedy for the first 6 years of remedy implementation has

indicated that the P&T configuration needs to be modified to increase the capacity to recover and treat

carbon tetrachloride and ultimately accelerate progress toward attaining groundwater cleanup goals.

The purpose of the optimization study is to collect and interpret data to evaluate remedy performance

enhancement through P&T configuration changes associated with 200 West P&T operations. It is

intended that the results from the optimization study will provide a technical basis for recommendations

on whether to formally modify the P&T configuration and the associated remedy decision documents.

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Figure 1-2. 200-ZP-1 OU Optimization Study Long-Term Groundwater Monitoring Network

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The optimization study will be conducted consistent with U.S. Environmental Protection Agency (EPA)

guidelines provided in EPA 542-R-13-008, Remediation Optimization: Definition, Scope and Approach.

The 200-ZP-1 OU OSP (DOE/RL-2019-38) provides an overall approach to perform changes to the

treatment facility and the well network to increase carbon tetrachloride treatment capacity. Initial data

collection (beginning immediately following suspension of biological treatment at the 200 West P&T) is

being conducted under the OSP and DOE/RL-2009-115, Performance Monitoring Plan for the 200-ZP-1

Groundwater Operable Unit Remedial Action (hereinafter referred to as the 200-ZP-1 OU performance

monitoring plan [PMP]) (as amended by TPA-CN-0875). This SAP specifies the optimization study

long-term groundwater monitoring data collection activities. As data are gathered during the study,

adjustments to the sampling and analysis approach may be made, if needed, to achieve optimization

study objectives.

The 200-ZP-1 OU OSP (DOE/RL-2019-38) lists four tasks to be conducted:

Task 1: Suspend active biological treatment at the 200 West P&T, prepare study implementation

documents, and install new extraction/injection wells.

Task 2: Perform facility and well network upgrades to enable increased treatment capacity at the

200 West P&T.

Task 3: Collect data and perform monitoring.

Task 4: Prepare reports.

The activities detailed in this SAP are intended to support Task 3 and will be documented as part of

Task 4. Long-term monitoring under this SAP will include obtaining data currently collected through

existing SAPs as well as analyzing samples from existing wells for analytes not currently collected under

existing SAPs. The frequency of sample collection will also increase at various wells under this SAP.

The primary data collection elements for Task 3 include information from the 200 West P&T (influent

and effluent COC concentrations, as well as additional process operational monitoring data), COC mass

recovery data, aquifer hydraulic head data, and constituent concentrations at monitoring wells over the

period of data collection. Data collection efforts under this SAP are limited to those associated with the

optimization study long-term groundwater monitoring, as discussed in Chapters 2 and 3.

In Task 4, the data generated under Task 3 will be analyzed, interpreted, and compared to outputs from

fate and transport (F&T) modeling. The F&T analysis is used to evaluate the effect of the P&T

configuration changes made during the optimization study. The analyses include hydraulic trends,

gradients, drawdown, and flow and capture; evaluation of temporal trends and spatial distribution of

constituents; and mass recovery. Data evaluations will occur following data collection in order to make

adjustments to data collection or operations, including groundwater monitoring, if needed.

1.1.1 Remedy Implementation Documentation

The 200-ZP-1 OU remedy is implemented through multiple implementation documents, including

the following:

DOE/RL-2008-78, Rev. 1 (200-ZP-1 P&T RD/RAWP)

DOE/RL-2019-23 (Ringold A SAP)

DOE/RL-2019-38 (200-ZP-1 OU OSP)

DOE/RL-2009-115 (200-ZP-1 OU PMP)

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DOE/RL-2009-124, 200 West Pump and Treat Operations and Maintenance Plan (hereinafter

referred to as the 200 West P&T operations and maintenance [O&M] plan)

Reporting activities are provided through annual P&T reports, quarterly regulatory briefings, and an

annual P&T remedy progress assessment report. Changes to the P&T configuration performed as part of

the optimization study may require revisions to the 200-ZP-1 OU PMP (DOE/RL-2009-115) and the

200 West P&T O&M plan (DOE/RL-2009-124).

Figure 1-3 shows the relationship between 200-ZP-1 OU remedy implementation documents and remedy

reporting, optimization, decisions, and management. As shown in the figure, the 200-ZP-1 P&T

RD/RAWP (DOE/RL-2008-78, Rev. 1) describes the remedy tasks and provides the overall direction for

remedy implementation to meet 200-ZP-1 OU ROD (EPA et al., 2008) requirements. The 200-ZP-1 OU

PMP (DOE/RL-2009-115) and the 200 West P&T O&M plan (DOE/RL-2009-124) guide the approach

for remedy implementation. Specifically, the PMP describes data collection and interpretation to conduct

remedy performance assessment and support remedy implementation decisions. The O&M plan guides

operation and data collection for the 200 West P&T, as well as the injection and extraction well networks.

The PMP provides the requirements that the O&M plan must incorporate to meet plume remediation

needs. The O&M plan activities provide data to the PMP for use in performance assessment.

1.1.2 Scope

The 200-ZP-1 OU OSP (DOE/RL-2019-38) provides an overall approach to conduct well network

optimization to increase carbon tetrachloride recovery and treatment capacity and to perform necessary

changes at the treatment facility. Appendix A of this SAP provides the DQOs which support the OSP.

This SAP was developed to detail the sampling and analysis activities necessary to support the

optimization study long-term groundwater monitoring data collection needs of the OSP. Data collection

efforts under this SAP are limited to those activities associated with the 200-ZP-1 OU optimization study

long-term groundwater monitoring and are detailed in Chapters 2 and 3. Activities included in this SAP

are intended to support OSP Task 3 and will be documented as part of OSP Task 4. Figure 1-2 depicts the

200-ZP-1 OU optimization study long-term groundwater monitoring well network.

The F&T analysis (OSP Task 4) will be used to evaluate the effect of the P&T configuration changes

made during the optimization study. The analyses include hydraulic trends, gradients, drawdown, and

flow and capture; evaluation of temporal trends and the spatial distribution of constituents; and mass

recovery. Data evaluations (including modeled F&T predictions) will occur following data collection in

order to make adjustments to data collection or operations, including groundwater monitoring, if needed.

Each new well installed in proximity to the 200-ZP-1 OU carbon tetrachloride plume during the

optimization study timeframe will be evaluated for inclusion in the study. Section 1.3.4 lists the steps to

be used in the well selection process.

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Figure 1-3. 200-ZP-1 OU Remedy Implementation and Reporting

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1.1.3 Objectives

The primary objectives of the sampling activities identified in this SAP include the following:

Obtain new and existing data to quantify the increased carbon tetrachloride mass removal rate and

concentration reductions under the optimization study configurations (e.g., increased extraction rate

and increased carbon tetrachloride treatment capacity).

Obtain new and existing data to compare anticipated remedy performance for carbon tetrachloride

under the optimization study configurations to pre-optimization study performance.

Obtain new and existing data to quantify nitrate plume behavior.

The comprehensive evaluation initiated in FY 2020 as a separate activity taking place concurrently with

the optimization study will provide a technical assessment of near- and long-term projected plume

remediation, COC treatment, and source contaminant requirements for other COCs and COPCs.

The resulting recommendations from this effort will develop the basis for additional remedy optimization

actions that will be integrated into necessary CERCLA decision documents and remedy optimization

efforts (anticipated to occur in the FY 2021/2022 timeframe) for relevant Central Plateau OUs, including

the 200-ZP-1 OU.

Data collected from existing wells under this SAP will be used to update groundwater elevation (contour)

maps, three-dimensional contaminant plume depictions, and F&T models.

Section 1.3 discusses the DQOs that guide this SAP.

1.2 Background

The 200 Areas are located on a broad, relatively flat plain that constitutes a local topographic high

commonly referred to as the Central Plateau. The 200-ZP-1 OU underlies the northern portion of the

200 West Area, which is located at the western side of the Central Plateau.

The 200-ZP-1 OU comprises groundwater contaminated by releases from facilities and waste sites

associated with Hanford Site former plutonium concentration and recovery operations at Z Plant

and plutonium separation operations at T Plant. The 200-ZP-1 OU includes several groundwater

contaminant plumes that span about 18 km2 (7 mi2) beneath the 200 West Area. Figure 1-1 shows the

location of the 200-ZP-1 OU at the Hanford Site. The main COC in groundwater for the 200-ZP-1 OU is

carbon tetrachloride.

The 200-ZP-1 OU remedy began operating in 2012 using the 200 West P&T. Overall performance of

200-ZP-1 OU P&T activities through the initial 6 years of operation demonstrated that flow rates, plume

containment, and mass extraction performance are consistent with the targets established in the

200-ZP-1 P&T RD/RAWP (DOE/RL-2008-78, Rev. 0 REISSUE). However, data and information

obtained following issuance of the 200-ZP-1 OU ROD (EPA et al., 2008) suggest that conditions are less

favorable for attaining the carbon tetrachloride cleanup level with the current P&T configuration in the

timeframe specified in the ROD. In addition, active biological treatment limited plant throughput and was

not needed to remediate carbon tetrachloride. This data and information include the following:

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The site-specific abiotic degradation rate of carbon tetrachloride (as presented in PNNL-22062,

Abiotic Degradation Rates for Carbon Tetrachloride and Chloroform: Final Report) has been

determined to be about an order of magnitude slower than the degradation rate assumed in the

200-ZP-1 OU FS (DOE/RL-2007-28). As a result of the slower natural degradation rate, more

intensive P&T efforts and/or a longer cleanup duration are needed to achieve the carbon tetrachloride

cleanup levels specified in the 200-ZP-1 OU ROD (EPA et al., 2008).

More carbon tetrachloride contamination is present in Rwie than was identified in the 200-ZP-1 OU

FS (Section 2.4 in DOE/RL-2007-28). Current estimates indicate that over a third more carbon

tetrachloride mass resides within the Rwie than was assumed in the 200-ZP-1 OU FS.

A predictive groundwater F&T modeling analysis was conducted using this new information to evaluate

whether the current P&T configuration could meet the remedial action objectives (RAOs) identified in the

200-ZP-1 OU ROD (EPA et al., 2008) for carbon tetrachloride, which is the primary risk driver and has

a high concentration relative to the cleanup level and a corresponding large mass within the aquifer.

The analysis indicated that without modification, carbon tetrachloride concentrations would not meet

cleanup levels within the 125-year timeframe. The analysis also suggested that sufficient nitrate treatment

may have occurred to transition to MNA, based on nitrate concentrations being less than an order of

magnitude above the cleanup level and the significant amount of nitrate removed from the aquifer as of

the end of December 2019.

The predictive analysis resulted in an initial evaluation of P&T configuration changes to focus on

increasing the carbon tetrachloride treatment capacity of the 200 West P&T to diminish the plume in

the Rwie. To improve carbon tetrachloride cleanup, a third air stripper tower and additional extraction

and injection wells are required to accommodate greater total overall operating capacity for the

200 West P&T. The 200 West P&T is currently operating at its original design capacity of 9,500 L/min

(2,500 gal/min) maximum throughput, but only 6,800 L/min (1,800 gal/min) are available for the

200-ZP-1 OU due to water being treated from other feed streams. In addition, nitrate in groundwater is

currently present primarily at concentrations less than an order of magnitude above the cleanup level.

Considering current nitrate concentration trends and assuming there is no continuing source of nitrate,

sufficient nitrate may have already been removed from the aquifer to enable a transition to the MNA

phase of the remedy that will still allow the nitrate cleanup level to be reached within the timeframe

specified in the 200-ZP-1 OU ROD (EPA et al., 2008). It is anticipated that suspending active biological

treatment will allow resources to be focused to expand the well network and increase the P&T capacity

for carbon tetrachloride to approximately 14,200 L/min (3,750 gal/min), with the 200-ZP-1 OU treatment

capacity to increase to 11,621 L/min (3,070 gal/min).

Plume dynamics for COCs from water quality data collected and evaluated under the 200-ZP-1 OU PMP

(DOE/RL-2009-115) will be used to predict whether RAOs are expected to be achieved for all of the

COCs under the optimization study configurations within the timeframe in the 200-ZP-1 OU ROD

(EPA et al., 2008). In addition, a comprehensive evaluation has been initiated to provide a technical

assessment of near- and long-term projected plume remediation, COC treatment, and source contaminant

requirements for other COCs and COPCs (SGW-65172-VA).

As previously noted, new data collected since issuance of the 200-ZP-1 P&T RD/RAWP

(DOE/RL-2008-78, Rev. 0 REISSUE) show that more carbon tetrachloride contamination is present in

the lower Rwia portion of the aquifer than was identified in the 200-ZP-1 OU FS (Section 2.4 in

DOE/RL-2007-28). Current estimates indicate that approximately 25% of the remaining carbon

tetrachloride mass resides within the Rwia compared to approximately 12% assumed in the 200-ZP-1 OU

FS. The data also indicate lower hydraulic conductivity in the Rwia aquifer when compared to the Rwie,

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causing additional remediation difficulties. The Ringold A SAP (DOE/RL-2019-23) was developed to

better characterize the Rwia. Characterization activities under the Ringold A SAP are planned to be

performed concurrently with the 200-ZP-1 OU optimization study.

The following sections summarize the hydrogeology, groundwater flow, contaminant plumes, and

contamination sources for the 200-ZP-1 OU. A summary of the DQO process and outcomes is

also provided.

1.2.1 Site Geology/Hydrology

The Hanford Site lies in a sediment-filled basin on the Columbia Plateau in southeastern Washington

State (Figure 1-1). The Central Plateau is a relatively flat, prominent terrace near the center of the

Hanford Site. The Columbia River Basalt Group and a sequence of overlying sediments comprise the

local geology. The overlying sediments are approximately 169 m (555 ft) thick, with surface elevations

ranging from approximately 200 to 217 m (660 to 712 ft). The sediment thickness in the 200 West Area

above the water table ranges from 40 to 75 m (132 to 246 ft). Sediments in the vadose zone include the

Ringold Formation (the uppermost Rwie and the Ringold upper mud unit), the Cold Creek unit, and the

Hanford formation.

Groundwater beneath the 200 West Area is primarily found in unconfined and semiconfined sedimentary

aquifer systems and in deeper confined aquifers within the basalt. The unconfined aquifer in the

200-ZP-1 OU primarily occurs in the Rwie. The low-permeability Rlm forms the base of the unconfined

aquifer in much of the 200-ZP-1 OU. Where present, the Rlm is a semiconfining unit that separates and

distinguishes the conditions and contaminants above the unit from those below it in the semiconfined

aquifer, which resides in the Rwia. However, the Rlm is not present in some portions of the OU, and the

unconfined aquifer extends into the Rwia in these areas.

1.2.2 Groundwater Flow

Groundwater in the unconfined aquifer flows from areas where the water table is higher (west of the

Hanford Site) to areas where the water table is lower (the Columbia River), with velocities typically

ranging from 0.0001 to 0.5 m/d (0.00033 to 1.64 ft/d). Groundwater flow through the Central Plateau

generally occurs in a predominantly easterly direction, with velocities approximating 0.0001 m/d

(0.0003 ft/d) in fine-textured, lower permeability Ringold sediments (SGW-38815, Water-Level

Monitoring Plan for the Hanford Site Soil and Groundwater Remediation Project). The depth of the

water table in the 200 West Area varies from about 50 m (164 ft) in the southwest corner (near the former

216-U-10 Pond) to >100 m (328 ft) to the north.

1.2.3 Sources of Contamination

The 200-ZP-1 OU includes several groundwater contaminant plumes collectively covering an area of

approximately 18 km2 (7 mi2) beneath much of the 200 West Area. The 200 West Area contains waste

management facilities and former irradiated fuel-reprocessing facilities. The major waste streams that

contributed to groundwater contamination were associated with plutonium-finishing operations at the

Z Plant facilities and the plutonium separation operations at the T Plant facilities in the 200 West Area.

Liquid waste disposal to cribs and trenches near these facilities resulted in several groundwater

contaminant plumes in the 200-ZP-1 OU.

The groundwater COCs identified in the 200-ZP-1 OU ROD (EPA et al., 2008) include carbon

tetrachloride, total chromium, hexavalent chromium, iodine-129, nitrate, technetium-99, trichloroethene

(TCE), and tritium. The primary carbon tetrachloride and TCE sources were associated with liquid waste

discharges from plutonium separation processes at the Plutonium Finishing Plant to the 216-Z-1A,

216-Z-9, and 216-Z-18 Cribs and Trenches. These sources have been mitigated and there is no longer

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a continuing carbon tetrachloride source that would contribute to a plume of concern (DOE/RL-2014-48,

Response Action Report for the 200-PW-1 Operable Unit Soil Vapor Extraction Remediation).

The carbon tetrachloride plume area is about 18 km2 (7 mi2) and primarily extends north, south, and east

from the source areas.

Sources of chromium, iodine-129, nitrate, TCE, technetium-99, and tritium contamination in the

200-ZP-1 OU include releases from past leaks in single-shell tanks and pipelines in Waste Management

Areas T and TX-TY, and liquid waste disposal from plutonium-processing operations to cribs and

trenches adjacent to the waste management areas. Except for nitrate, the remaining contaminant plumes in

the 200-ZP-1 OU are predominately located within the boundaries of the carbon tetrachloride plume.

1.2.4 Contaminant Plumes

To support performance evaluation of the 200-ZP-1 OU remedy, 98 monitoring wells are currently

monitored and sampled within the footprint of the 200-ZP-1 and 200-UP-1 OUs. Data obtained during

and following remedial investigations and identified in the 200-ZP-1 OU FS (DOE/RL-2007-28) indicate

that groundwater contamination was present from the water table to the base of the unconfined aquifer

(DOE/RL-2008-78, Rev. 0 REISSUE).The uppermost aquifer in the 200-ZP-1 OU is unconfined and

occurs primarily within the Rwie but also contiguously within the Rwia where the intervening Rlm

is absent.

Carbon tetrachloride is the predominant COC and is the primary risk driver in the 200-ZP-1 OU, with the

largest estimated lateral and vertical extent at concentrations substantially greater than its cleanup level.

Figure 1-4 shows the footprint of the carbon tetrachloride plume in planar view. Figures 1-5 and 1-6 show

cross sections focused on the upper portion of the unconfined aquifer above the Rlm. However, moving

from west to east, the vertical extent of carbon tetrachloride increases in many places, and concentrations

exceeding the cleanup levels specified in the 200-ZP-1 OU ROD (EPA et al., 2008) extend throughout the

entire aquifer thickness, including depths both above and below the Rlm (DOE/RL-2008-78, Rev. 1).

Groundwater sample data obtained following completion of the 200-ZP-1 OU FS (DOE/RL-2007-28)

indicate that carbon tetrachloride is present over a wider area and at concentrations more than two orders

of magnitude greater than the cleanup level (particularly in eastward locations) as compared to

interpretations of available data at the time of FS completion. In particular, data obtained from the

installation of the injection, extraction, and monitoring wells on the east side of the 200-ZP-1 OU

indicated that higher concentrations of carbon tetrachloride were present below the Rlm. Where it is

present, downward plume migration is typically limited by the relatively fine-grained Rlm, which is

interpreted as forming a hydraulic barrier to vertical groundwater flow. However, the Rlm is

discontinuous and relatively thin in places, which provided a pathway for the carbon tetrachloride plume

to migrate downward to the basalt bedrock in areas where the Rlm is not present. Improved knowledge of

the three-dimensional carbon tetrachloride extent suggests that a greater proportion of the total carbon

tetrachloride mass may reside at elevations beneath (and possibly within) the Rlm when compared to the

interpretations based on data available when the 200-ZP-1 OU FS was completed.

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Figure 1-4. Two-Dimensional Model Prediction of 200-ZP-1 OU Carbon Tetrachloride Plume

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Figure 1-5. Hydrogeologic Three-Dimensional Model Cross Section of Carbon Tetrachloride Plume, North to South (A to A′)

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Figure 1-6. Hydrogeologic Three-Dimensional Model Cross Section of Carbon Tetrachloride Plume, West to East (B to B′)

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1.3 Data Quality Objective Summary

The DQO process is a strategic planning approach used to define the criteria that a data collection design

should satisfy. This process is used to ensure that the type, quantity, and quality of the environmental data

used in decision making will be appropriate for the intended application. The DQOs for this SAP were

developed in accordance with EPA/240/B-06/001, Guidance on Systematic Planning Using the Data

Quality Objectives Process (EPA QA/G-4). The DQO process involves a series of logical steps used to

plan for the resource-effective acquisition of environmental data. The performance and acceptance criteria

are determined through the DQO process, which serves as the basis for designing the plan to collect data

of sufficient quality and quantity to support project goals. Appendix A of this SAP presents the DQO

process used to support the sample design presented in this SAP.

This SAP identifies groundwater data collection efforts that support the 200-ZP-1 OU OSP

(DOE/RL-2019-38). Samples collected as part of this SAP will be used to support decisions related to

remedy performance and optimization in the Rwie. Sample analysis includes carbon tetrachloride and

anions (nitrate, nitrite, chloride, and sulfate) for all wells and biofouling indicators (total organic carbon,

manganese, and nickel) for select wells in the optimization study long-term groundwater monitoring

network. This section presents the key outputs resulting from the DQO process.

1.3.1 Statement of the Problem

Data and information obtained during the first 6 years of P&T remedy implementation in the

200-ZP-1 OU suggest that conditions within the OU are less favorable for attaining RAOs and cleanup

levels for carbon tetrachloride within the timeframes identified in the 200-ZP-1 OU ROD

(EPA et al., 2008). The main factors contributing to these conditions include an order of magnitude

slower abiotic degradation rate and a larger extent and mass of carbon tetrachloride relative to the

assumptions used in the 200-ZP-1 OU FS (DOE/RL-2007-28). In addition, most nitrate in groundwater is

currently present at concentrations less than an order of magnitude above the cleanup level. Considering

current nitrate concentration trends and assuming there is no continuing source of nitrate, sufficient nitrate

may have already been removed from the aquifer to enable a transition to the MNA phase of the remedy

that will still allow the nitrate cleanup level to be reached within the timeframe specified in the

200-ZP-1 OU ROD (EPA et al., 2008). As a result, data are needed to provide a technical basis showing

optimization of the 200-ZP-1 OU P&T remedy performance that increases carbon tetrachloride treatment

capacity and accelerates mass removal, achieving the cleanup levels. In addition, biofouling parameter

data are required to evaluate whether continued disinfection of injection wells is warranted.

A significant amount of nitrate in the 200-ZP-1 OU (2,186,276 kg) (SGW-64504-VA, 200 West Pump

and Treat Facility – 4th Quarter CY2019 Briefing) has been extracted and treated by the P&T system

since the beginning of remedy operations, and the nitrate plume may have been sufficiently diminished

such that active nitrate treatment is no longer needed to meet the RAOs identified in the 200-ZP-1 OU

ROD (EPA et al., 2008). Therefore, an evaluation of suspending the active biological treatment

component of the 200 West P&T and transitioning to MNA for nitrate is warranted and additional anion

data, including nitrate, are required.

1.3.2 Project Task and Problem Definition

The data gathered under this SAP will address the 200-ZP-1 OU optimization study long-term

groundwater monitoring data collection needs. Table 1-1 lists the seven principal study questions (PSQs)

presented in Appendix A of this SAP for the 200-ZP-1 OU OSP (DOE/RL-2019-38). Data collection

under this SAP will address PSQs #1, #4, and #5.

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Table 1-1. Principal Study Questions

PSQ # Principal Study Question

Data Collection

Addressed in

This SAP?

1

Can a technical basis be prepared showing a desired carbon tetrachloride mass removal

rate along with associated plume area and concentration reductions under the

optimization study configurations using existing data collection strategies

(DOE/RL-2009-115; DOE/RL-2009-124)?

Yes

2

Can a technical basis be prepared that sufficiently evaluates the effectiveness of carbon

tetrachloride plume containment under the optimization study configurations using

existing data collection strategies (DOE/RL-2009-115; DOE/RL-2009-124)?

No

3

Can a technical basis be prepared that sufficiently evaluates injection well

performance (e.g., specific injection capacity) under the optimization study

configurations when compared to pre‑optimization study performance?

No

4

Can a technical basis be prepared that compares anticipated remedy performance for

carbon tetrachloride under the optimization study configurations with predicted

pre-optimization study performance?

Yes

5

Can a technical basis be prepared showing nitrate plume behavior under the

optimization study configurations to confirm that transition to MNA is appropriate

for nitrate?

Yes

6 Can a technical basis be prepared that confirms treated effluent quality meets injection

criteria (except for nitrate)? ? No

7

Can a technical basis be prepared that predicts whether RAOs are expected to be

achieved for all COCs under the optimization study configurations within the

timeframe of the 200‑ZP‑1 OU ROD (EPA et al., 2008) ?

No

References:

DOE/RL-2009-115, Performance Monitoring Plan for the 200-ZP-1 Groundwater Operable Unit Remedial Action.

DOE/RL-2009-124, 200 West Pump and Treat Operations and Maintenance Plan.

EPA et al., 2008, Record of Decision Hanford 200 Area 200-ZP-1 Superfund Site, Benton County, Washington.

Note: Data collection under this SAP will address only PSQs #1, #4, and #5. Data collection for PSQ’s #2, #3, #6 and #7 are

referenced in Appendix A of this SAP.

COC = contaminant of concern

MNA = monitored natural attenuation

OU = operable unit

PSQ = principal study question

RAO = remedial action objective

ROD = Record of Decision

SAP = sampling and analysis plan

1.3.3 Decision Statements and Decision Rules

The DQO process identifies the key decisions and goals that must be addressed to achieve the final

solution to the problem statement. As stated in the 200-ZP-1 OU ROD (EPA et al., 2008), the selected

remedy combines P&T, MNA, flow-path control, and institutional controls. This SAP addresses

optimization study long-term groundwater monitoring and associated data collection to solve the problem

statement. The key questions that the data collection must address and the alternative actions that may

result from the data analysis are presented in decision statements (DSs).

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The DSs consolidate potential questions and alternative actions. Decision rules (DRs) are generated from

the DSs. A DR is an “IF…THEN…ELSE” statement incorporating the parameter of interest, unit of

decision making, action level, and actions resulting from resolution of the decision. The DRs define the

logic for how the data will be used to draw conclusions from the sampling effort. Tables 1-2 and 1-3

present the DSs and DRs, respectively, as identified during the DQO process to be addressed in this SAP.

Appendix A presents the PSQs and alternative actions used to develop the DSs and DRs. Table 1-4

presents the data inputs to resolve the DSs.

Table 1-2. Decision Statements

DS # Decision Statement

Data Collection

Addressed in

This SAP?

1

Determine if a technical basis can be prepared showing a desired carbon tetrachloride

mass removal rate along with associated plume area and concentration reductions under

the optimization study configurations using existing data collection strategies

(DOE/RL‑2019‑115; DOE/RL‑2009‑124); then prepare the report as required under

Task 4 of the 200‑ZP‑1 OU OSP; else, collect supplemental data to define the optimum

carbon tetrachloride mass removal rate along with associated plume area and

concentration reductions and prepare the report.

Yes

2

Determine if a technical basis can be prepared that sufficiently evaluates the

effectiveness of carbon tetrachloride plume containment under the optimization study

configurations using existing data collection strategies (DOE/RL‑2019‑115;

DOE/RL‑2009‑124); then prepare the report as required under Task 4 of the

200‑ZP‑1 OU OSP; else, collect supplemental data to evaluate the effectiveness of

carbon tetrachloride plume containment and prepare the report.

No

3

Determine if a technical basis can be prepared that sufficiently evaluates injection well

performance (e.g., specific injection capacity) under the optimization study

configurations when compared to pre‑optimization study performance; then prepare the

report as required under Task 4 of the 200‑ZP‑1 OU OSP; else, collect supplemental

data until a technical basis can be prepared that sufficiently evaluates injection well

performance and prepare the report.

No

4

Determine if a technical basis can be prepared that compares anticipated remedy

performance for carbon tetrachloride under the optimization study configurations with

predicted pre‑optimization study performance; then prepare the report as required under

Task 4 of the 200‑ZP‑1 OU OSP; else, collect supplemental data until a technical basis

can be prepared that compares anticipated remedy performance for carbon tetrachloride

and prepare the report.

Yes

5

Determine if a technical basis can be prepared showing nitrate plume behavior under

the optimization study configurations to confirm that transition to MNA is appropriate

for nitrate; then prepare the report as required under Task 4 of the 200‑ZP‑1 OU; else,

collect supplemental data until a technical basis can be prepared showing nitrate plume

behavior can transition to MNA and prepare the report.

Yes

6

Determine if a technical basis can be prepared confirming that treated effluent quality

meets injection criteria (except for nitrate); then prepare the report as required under

Task 4 of the 200‑ZP‑1 OU OSP; else, collect supplemental data until a technical basis

can be prepared that confirms treated effluent quality meets injection criteria (except for

nitrate) and prepare the report.

No

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Table 1-2. Decision Statements

DS # Decision Statement

Data Collection

Addressed in

This SAP?

7

Determine if a technical basis can be prepared that predicts whether RAOs are expected

to be achieved for all of the COCs under the optimization study configurations within

the timeframe of the 200‑ZP‑1 OU ROD (EPA et al., 2008); then prepare the report as

required under Task 4 of the 200‑ZP‑1 OU OSP; else, collect supplemental data until

a technical basis can be prepared that predicts whether RAOs are expected to be

achieved for all COCs and prepare the report.

No

References:



EPA et al., 2008, Record of Decision Hanford 200 Area 200-ZP-1 Superfund Site, Benton County, Washington.


DS = decision statement


OSP = optimization study plan

OU = operable unit




Table 1-3. Decision Rules

DS # DR # Decision Rule

Data Collection

Addressed in

This SAP?

1 1

If the data confirm the desired carbon tetrachloride mass removal rate along

with associated plume area and concentration reductions are achieved under

the optimization study configurations; then prepare the report as required

under Task 4 of the 200‑ZP‑1 OU OSP; else, collect supplemental data until

a technical basis can define the optimum carbon tetrachloride mass removal

rate along with associated plume area and concentration reductions.

Yes

2 2

If the data confirm a technical basis can be prepared that sufficiently evaluates

the effectiveness of carbon tetrachloride plume containment under the

optimization study configurations; then prepare the report as required under

Task 4 of the 200‑ZP‑1 OU OSP; else, collect supplemental data until

a technical basis can be prepared that sufficiently evaluates the effectiveness

of carbon tetrachloride plume containment.

No

3 3

If the data confirm a technical basis can be prepared that sufficiently evaluates

injection well performance (e.g., specific injection capacity) under the

optimization study configurations when compared to pre‑optimization study

performance; then prepare the report as required under Task 4 of the

200‑ZP‑1 OU OSP; else, collect supplemental data until a technical basis can

prepared that sufficiently evaluates injection well performance.

No

4 4

If the data confirm a technical basis can be prepared that compares anticipated

remedy performance for carbon tetrachloride under the optimization study

configurations with predicted pre‑optimization study performance; then

prepare the report as required under Task 4 of the 200‑ZP‑1 OU OSP; else,

collect supplemental data until a technical basis can be prepared that compares

anticipated remedy performance for carbon tetrachloride.

Yes

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Table 1-3. Decision Rules


Data Collection

Addressed in

This SAP?

5 5

If the data confirm a technical basis can be prepared showing nitrate plume

behavior under the optimization study configurations to confirm that transition

to MNA is appropriate for nitrate; then prepare the report as required under

Task 4 of the 200‑ZP‑1 OU OSP; else, collect supplemental data until

a technical basis can be prepared showing nitrate plume behavior can

transition to MNA.

Yes

6 6

If the data support a technical basis confirming that treated effluent quality

meets injection criteria (except for nitrate); then prepare the report as required

under Task 4 of the 200‑ZP‑1 OU OSP; else, collect supplemental data until

a technical basis can be prepared that confirms treated effluent quality meets

injection criteria (except for nitrate).

No

7 7

If the results confirm a technical basis can be prepared that predicts whether

RAOs are expected to be achieved for all of the COCs under the optimization

study configurations within the timeframe of the 200‑ZP‑1 OU ROD

(EPA et al., 2008); then prepare the report as required under Task 4 of the

200‑ZP‑1 OU OSP; else, continue collect supplemental data until a technical

basis can be prepared that predicts whether RAOs are expected to be achieved

for all COCs.

No

Reference: EPA et al., 2008, Record of Decision Hanford 200 Area 200-ZP-1 Superfund Site, Benton County, Washington.


DR = decision rule




OU = operable unit




Table 1-4. Summary of Data Inputs to Resolve DSs

Data Inputs DS #

Data Collected

Under This SAP?

Data Collection Specified in this SAP

Water quality (contaminant) sample results from monitoring wells 1, 2, 3, 4, and 5

Yes

(DS #1, #4,

and #5)*

Water quality (contaminant) sample results from extraction wells

(collected via the 200 West P&T O&M plan [DOE/RL-2009-124]) 1, 2, 4, and 5 No

Injection well flow rates, pressures, and total run times (collected via the

200 West P&T O&M plan [DOE/RL-2009-124]) 3 No

Treatment plant influent flow rates (collected via the 200 West P&T

O&M plan [DOE/RL-2009-124]) 5 No

Treatment plant influent water quality (contaminant) sample results

(collected via the 200 West P&T O&M plan [DOE/RL-2009-124]) 5 No

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Table 1-4. Summary of Data Inputs to Resolve DSs

Data Inputs DS #

Data Collected

Under This SAP?

Water levels measured in monitoring wells for use in developing

groundwater elevation (contour) maps prepared under the

200-ZP-1 OU PMP (DOE/RL-2009-115).

1, 2, and 5 Yes

(DS #1 and #5)*

Water levels measured in extraction and injection wells (collected via the

200 West P&T O&M plan [DOE/RL-2009-124]) 1, 2, and 5 No

Data Used Primarily as Input to the Model

The most current three-dimensional contaminant plume depictions

constructed from the groundwater contaminant sampling data for each

contaminant of concern and mass recovery data

4 Yes

Data Used Directly in Calculations and as Input to the Model

Extraction well and injection well flow rate data (collected via the 200

West P&T O&M plan [DOE/RL-2009-124]) 1, 2, 3, 4, and 5 No

Additional Data

Logs of well rehabilitation activities and results 3 No

Plume dynamics for contaminants of concern from water quality data

collected and evaluated under the performance monitoring plan 7 No

References:



*Data collection activities for DS #2 and DS #3 are covered under the 200-ZP-1 OU PMP (DOE/RL-2009-115).


O&M = operations and maintenance

OU = operable unit

P&T = pump and treat

PMP = performance monitoring plan


1.3.4 Data Inputs and Sampling Design

The data gathered under this SAP will address the DSs identified in Table 1-2. Table 1-4 summarizes the

primary data inputs needed to resolve the DSs. Chapter 3 discusses the data collection efforts required to

resolve each DS, the estimated sampling frequency of wells selected for 200-ZP-1 OU optimization study

long-term groundwater monitoring, and the analyses to be performed on individual groundwater samples.

The 200-ZP-1 OU optimization study long-term groundwater monitoring strategy was developed in steps.

The process combined the evaluation of recent concentration time-series graphs from existing monitoring

wells and current groundwater concentration (spatial) patterns, and the use of predictive simulations

completed with Version 8.3 of the Plateau to River Groundwater Model (P2R Model) (CP-57037, Model

Package Report: Plateau to River Groundwater Model Version 8.3).

The specific steps taken to select wells for inclusion in the optimization study long-term groundwater

monitoring network began by querying a master list of potentially available monitoring wells from the

Hanford Environmental Information System (HEIS) database. The master list was restricted to wells that

reported at least one groundwater sample event during the 5-year period from the beginning of 2015

through the end of 2019. The master list contained a total of 184 wells for further consideration, including

monitoring wells from both the 200-ZP-1 and 200-UP-1 OUs.

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The master list was then reduced based on the locations of wells relative to each other, to the main area of

interest, and with regard to the availability of well as-built screen intervals. The review and reduction

were completed by a group of 200-ZP-1 OU subject matter experts as follows:

All monitoring wells located outside the area of interest were removed from the list.

Areas where several monitoring wells on the list were relatively closely spaced (clustered) were

further evaluated. Recent sampling frequency was taken into consideration, with priority for selection

given to a well currently sampled more frequently than other wells within the cluster and screened at

the appropriate depth. Wells that would likely provide redundant information (when considering their

proximity to each other and to injection and extraction wells) were removed from the list.

Wells without confirmed or confirmable as-built screen information were removed from the list.

This review reduced the initial master list of 184 monitoring wells to the 93 monitoring wells included in

the optimization study long-term monitoring well network shown in Figure 1-2. Table 1-5 lists the

200-ZP-1 OU optimization study long-term monitoring well network and the DSs to be addressed by the

data from each well. Each new well installed in proximity of the 200-ZP-1 OU during the optimization

study timeframe will be evaluated for inclusion in the study.

Table 1-5. 200-ZP-1 OU Optimization Study Long-Term Monitoring Well Network

Well Name PSQ #* Well Name PSQ #* Well Name PSQ #*

299-W10-1 1 and 4 299-W15-763 1 and 4 299-W22-86 1 and 4

299-W10-14 5 299-W15-765 1 and 4 299-W22-87 1 and 4

299-W10-27 1 and 4 299-W15-83 1 and 4 299-W22-88 1 and 4

299-W10-29 5 299-W15-94 1 and 4 299-W22-94 1 and 4

299-W10-30 5 299-W18-1 5 299-W22-95 1 and 4

299-W10-31 5 299-W18-16 5 299-W23-19 1 and 4

299-W11-18 1, 4, and 5 299-W18-21 5 299-W23-21 1 and 4

299-W11-33Q 1, 4, and 5 299-W18-22 5 299-W5-2P 1 and 4

299-W11-43 1 and 4 299-W18-40 5 299-W5-2Q 1 and 4

299-W11-45 1 and 4 299-W19-105 1 and 4 299-W6-11 5

299-W11-47 1 and 4 299-W19-107 1 and 4 299-W6-12 5

299-W11-48 1 and 4 299-W19-115 1 and 4 299-W6-17 1, 4, and 5

299-W11-87 1 and 4 299-W19-116 1 and 4 299-W6-3 5

299-W11-88 1 and 4 299-W19-123 1 and 4 299-W6-6 5

299-W13-1 1 and 4 299-W19-126 1 and 4 299-W7-3 5

299-W13-2P 1 and 4 299-W19-131 1 and 4 699-36-61A 5

299-W13-2Q 1 and 4 299-W19-34A 1 and 4 699-36-70B 1 and 4

299-W14-11 1 and 4 299-W19-34B 1 and 4 699-38-61 5

299-W14-14 1 and 4 299-W19-36 1 and 4 699-38-68A 1 and 4

299-W14-17 1 and 4 299-W19-4 1 and 4 699-38-70B 1 and 4

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Table 1-5. 200-ZP-1 OU Optimization Study Long-Term Monitoring Well Network

Well Name PSQ #* Well Name PSQ #* Well Name PSQ #*

299-W14-71 1 and 4 299-W19-41 1 and 4 699-38-70C 1 and 4

299-W14-72 1 and 4 299-W19-47 1 and 4 699-40-65 1 and 4

299-W15-11 1, 4, and 5 299-W19-48 1 and 4 699-43-69 1 and 4

299-W15-152 5 299-W19-49 1 and 4 699-44-64 1 and 4

299-W15-17 5 299-W19-6 1 and 4 699-44-70B 1 and 4

299-W15-224 5 299-W20-1 1 and 4 699-45-69A 1 and 4

299-W15-30 5 299-W21-2 1 and 4 699-45-69C 1 and 4

299-W15-37 1 and 4 299-W22-113 1 and 4 699-48-71 1 and 4

299-W15-46 1 and 4 299-W22-47 1 and 4 299-W15-44 5

299-W15-49 5 299-W22-72 1 and 4 699-48-77C 5

299-W15-50 1 and 4 299-W22-83 1 and 4 699-49-79 5

*The PSQs identified in DOE/RL-2019-38, 200-ZP-1 Operable Unit Optimization Study Plan, are as follows:

PSQ #1: Quantifying the increased carbon tetrachloride mass removal rate and the associated plume area and

concentration reductions under optimization study configurations.

PSQ #4: Comparing anticipated remedy performance for carbon tetrachloride under optimization study

configurations with predicted pre-optimization study

PSQ #5: Quantifying NO3 plume behavior under optimization study configurations to confirm transition to monitored

natural attenuation is appropriate for NO3 performance.

PSQ = principal study question

The reduced list of 93 monitoring wells (Figure 1-2) was further evaluated to determine the sampling

frequency and constituent reporting to provide the necessary sample data. The sampling frequency at

wells was developed to monitor changes in groundwater conditions resulting from the suspension of

active biological treatment for nitrate and increased groundwater extraction rate within the 200-ZP-1 OU

well network from approximately7,600 L/min (2,000 gal/min) to approximately 11,621 L/min

(3,070 gal/min).

The determination of appropriate sampling frequency was based on evaluating F&T simulation

completed using the P2R Model. Two contrasting models for P&T operating conditions were constructed

and executed to simulate the potential effects of increasing the capacity of the 200 West P&T system

and suspending active biological treatment of nitrate in the groundwater system. As detailed in

ECF-200ZP1-20-0056, Calculations to Support Monitoring Network and Sampling Frequency Planning

for the 200-ZP-1 Groundwater Operable Unit (OU) Optimization Study Period, the two models were

identical for historical conditions but differed in their assumed operations for projections commencing in

winter 2019 as follows:

The first (baseline) flow model was constructed to simulate the continuation of recent total 200 West

P&T treatment system capacity (approximately 9,464 L/min [2,500 gal/min]) and extraction and

injection within the 200-ZP-1 OU (approximately 7,600 L/min [2,000 gal/min]).

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The second (expanded) flow model was constructed to simulate future operating conditions with an

increased 200 West P&T total overall system capacity of approximately 13,173 L/min

(3,480 gal/min), and increased extraction and injection within the 200-ZP-1 OU of approximately

11,621 L/min (3,070 gal/min) facilitated by the addition of 10 hypothetical extraction wells.

The flow model was then used to make two sets of transport simulations to evaluate the F&T of the water

injected at the injection wells once active biological treatment of nitrate was suspended. In the first

simulation, the potential migration of the injected water was evaluated using the “unit plume” transport

simulation approach. For this analysis, a unit concentration (i.e., C = 1.0) was used to represent water

injected at the 200-ZP-1 OU injection wells. As water migrates away from the injection wells, the effects

of mixing and dispersion within the aquifer are simulated. As a result of the mixing and dispersion over

time and throughout space, the simulated concentration in groundwater represents the fraction of the

original water (i.e., of the injected water) that is present (after mixing and other processes) from that

which was injected at the well.

For the second simulation, the flow model was executed and then used to simulate the F&T of both

nitrate and carbon tetrachloride for the period from 2015 through 2137 using initial conditions

(three-dimensional plumes) representing conditions during 2015 (ECF-200ZP1-20-0056) for

each constituent.

Post-processing of both sets of simulations focused on preparing time-series plots of concentrations for

the reduced list of 93 monitoring wells. The second set of simulations calculated the concentrations of

nitrate and carbon tetrachloride directly. Because the first set of simulations used a “unit plume”

approach, it was necessary to convert the unit concentrations into approximate concentrations of nitrate

and carbon tetrachloride. Time-series concentrations at each monitoring well were approximated from the

“unit plume” simulations using the following equation:

𝑈𝐵𝑊𝑡 × 𝐸𝑉𝑁𝑂3 + (1 − 𝑈𝐵𝑊𝑡) × �̅�

where:

UBW = unit concentration simulated at each monitoring wells

EVNO3 = concentration of nitrate in the untreated effluent, which was assumed to be

120,000 mg/L (as nitrate [NO3])

Ā = average of the last four nitrate sample concentrations at the corresponding

monitoring well.

The time-series plots were then evaluated to identify monitoring wells with the highest potential to

provide data for each individual PSQ (defined in Appendix A of this SAP). Specifically, the nitrate

time-series plots, which compared measured nitrate concentrations (simulated predicted concentrations

and estimated timing of substantial concentration changes), were used to evaluate the probable nitrate

plume behavior under the expanded capacity and absent nitrate active treatment. The carbon tetrachloride

time-series plots were used to compare anticipated remedy performance under the increased capacity with

predicted performance without increased capacity, as well as to identify wells for which measurable

changes in carbon tetrachloride concentration may result during the optimization study period.

1.4 Target Analytes

Target analytes were selected to address the DSs (Table 1-1) and specific data inputs associated with the

optimization study long-term groundwater monitoring (Table 1-3). Table 1-6 lists the target analytes and

purpose for inclusion.

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Table 1-6. Analytes for 200-ZP-1 OU Optimization Study Long-Term Groundwater Monitoring

COC CAS Number Purpose

COCs

Carbon tetrachloride 56-23-5 Delineate carbon tetrachloride plume; optimization

study monitoring

Nitrate-N 14797-55-8 Delineate nitrate plume; optimization study monitoring

Other Constituents

Chloride 16887-00-6 Evaluate chlorinated solvent natural attenuation; optimization

study monitoring

Manganesea 7436-96-5 Evaluate natural attenuation; optimization study monitoring

Nickela 7440-02-0 Evaluate stainless-steel corrosion; optimization

study monitoring

Nitrite-N 14797-65-0 Evaluate nitrate natural attenuation; optimization

study monitoring

Sulfate 14808-79-8 Evaluate natural attenuation; optimization study monitoring

Total organic carbon TOC Evaluate natural attenuation; optimization study monitoring

Field Screening Parametersb

Dissolved oxygen N/A Evaluate natural attenuation and well purge for sampling

Oxidation-reduction potential N/A Evaluate natural attenuation

pH N/A Evaluate well purge for sampling

Specific conductance N/A Evaluate well purge for sampling

Temperature N/A Evaluate well purge for sampling

Turbidity N/A Evaluate well purge for sampling

a. Collect filtered and unfiltered samples for metals.

b. Field screening parameters to be collected in accordance with DOE/RL-96-68, Hanford Analytical Services Quality

Assurance Requirements Document, Vol. 3, Field Analytical Technical Requirements.

CAS = Chemical Abstracts Service


N/A = not applicable

TOC = total organic carbon

1.5 Project Schedule

The optimization study groundwater monitoring requirements have been divided into two phases:

near-term and long-term. The near-term groundwater sampling and analysis requirements were

implemented through TPA-CN-0875 for FY 2020 and are not included in this SAP. The long-term

groundwater monitoring for the 200-ZP-1 OU optimization study covered under this SAP is currently

expected to be completed over a period of 4 years (FY 2021 through FY 2024). However, as discussed in

Section 4.1.3 of the 200-ZP-1 OU OSP (DOE/RL-2019-38), additional time may be needed to collect

sufficient data to meet study objectives, which could result in the optimization study continuing for an

additional 2 years (through FY 2026).

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2 Quality Assurance Project Plan

A quality assurance project plan (QAPjP) establishes the quality requirements for environmental data

collection. It includes planning, implementation, and assessment of sampling tasks, field measurements,

laboratory analysis, and data review. This chapter describes the applicable environmental data collection

requirements and controls based on the quality assurance (QA) elements found in EPA/240/B-01/003,

EPA Requirements for Quality Assurance Project Plans (EPA QA/R-5); and DOE/RL-96-68, Hanford

Analytical Services Quality Assurance Requirements Document (HASQARD). DoD/DOE, 2019,

Department of Defense (DoD) Department of Energy (DOE) Consolidated Quality Systems Manual

(QSM) for Environmental Laboratories (hereinafter referred to as the DoD/DOE Quality Systems Manual

[QSM]), is also discussed. Section 7.8 of the Hanford Federal Facility Agreement and Consent Order

Action Plan (Tri-Party Agreement Action Plan) (Ecology et al., 1989b) requires QA/quality control (QC)

and sampling and analysis activities to specify the QA requirements for past-practice processes. This

QAPjP also describes applicable requirements and controls based on guidance in Ecology Publication

No. 04-03-030, Guidelines for Preparing Quality Assurance Project Plans for Environmental Studies;

and EPA/240/R-02/009, Guidance for Quality Assurance Project Plans (EPA QA/G-5). This QAPjP

supplements the contractor’s environmental QA program plan.

This QAPjP includes the following sections that describe the quality requirements and controls applicable

to Hanford Site OU sampling activities:

Section 2.1, “Project Management”

Section 2.2, “Data Generation and Acquisition”

Section 2.3, “Assessment and Oversight”

Section 2.4, “Data Review and Usability”

2.1 Project Management

The section includes project goals, planned management approaches, and planned output documentation.

2.1.1 Project/Task Organization

The contractor or its approved subcontractor is responsible for planning, coordinating, sampling, and

shipping samples to the laboratory. The contractor is also responsible for preparing and maintaining

configuration control of the SAP and assisting the U.S. Department of Energy, Richland Operations

Office (DOE-RL) project manager in obtaining approval of the SAP and future proposed revisions to

the SAP. The project organization is described in the following sections and is shown in Figure 2-1.

2.1.1.1 Regulatory Lead

The lead regulatory agency for the 200-ZP-1 OU is EPA. The lead regulatory agency is responsible for

regulatory oversight of cleanup projects and activities. EPA retains approval authority for all SAPs.

EPA works with DOE-RL to resolve concerns regarding the work described in this SAP in accordance

with Ecology et al., 1989a, Hanford Federal Facility Agreement and Consent Order

(Tri-Party Agreement).

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Figure 2-1. Project Organization

2.1.1.2 DOE-RL Manager

Hanford Site cleanup for the 200-ZP-1 OU is the responsibility of DOE-RL. The DOE-RL manager is

responsible for authorizing the contractor to perform activities described in this SAP at the Hanford Site

under CERCLA, RCRA, the AEA, and the Tri-Party Agreement (Ecology et al., 1989a).

2.1.1.3 DOE-RL Project Lead

The DOE-RL project lead is responsible for providing day-to-day oversight of the contractor’s

performance of the work scope, working with the contractor to identify and work through issues, and

providing technical input to DOE-RL management.

2.1.1.4 Remedy Selection and Implementation Project Director

The Remedy Selection and Implementation project director provides oversight and coordinates with

DOE-RL and primary contractor management in support of sampling and reporting activities.

The Remedy Selection and Implementation project director also provides support to the OU project

manager to ensure that work is performed safely and cost effectively.

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2.1.1.5 Operable Unit Project Manager

The OU project manager (or designee) is responsible and accountable for project-related activities

including coordinating with DOE-RL, the regulatory agencies, and contractor management in support

of sampling activities to ensure that work is performed safely, compliantly, and cost effectively.

In addition, the OU project manager (or designee) is also responsible for managing sampling documents

and requirements, field activities, and subcontracted tasks, as well as for ensuring that the project file is

properly maintained.

2.1.1.6 Operable Unit Technical Lead

The OU technical lead is responsible for developing the specific sampling design, analytical

requirements, and QC requirements, either independently or as defined through a systematic planning

process. The OU technical lead ensures that sampling and analysis activities (as delegated by the

OU project manager) are carried out in accordance with the SAP and works closely with the

environmental compliance officer, QA, Health and Safety, the field work supervisor (FWS), and the

Sample Management and Reporting (SMR) organization to integrate these and other technical disciplines

in planning and implementing the work scope.

2.1.1.7 Sample Management and Reporting

The SMR organization oversees offsite analytical laboratories, coordinates laboratory analytical work to

ensure that laboratories conform to the requirements of this plan, and verifies that laboratories are

qualified to perform Hanford Site analytical work. SMR generates field sampling documents, labels, and

instructions for field sampling personnel and develops the sample authorization form, which provides

information and instructions to the analytical laboratories. SMR ensures that field sampling documents

are revised to reflect approved changes. SMR receives analytical data from the laboratories, ensures that

the data are appropriately reviewed, performs data entry into the HEIS database, and arranges for data

validation and recordkeeping. SMR is responsible for resolving sample documentation deficiencies or

issues associated with Field Sample Operations (FSO), laboratories, or other entities. SMR is also

responsible for informing the OU project manager of any issues reported by the analytical laboratories.

2.1.1.8 Field Sampling Operations

FSO is responsible for planning and coordinating field sampling resources. The FWS directs the nuclear

chemical operators (samplers) who collect samples in accordance with this SAP and corresponding

standard methods and work packages. The FWS ensures that deviations from field sampling documents or

issues encountered in the field are documented appropriately (e.g., in the field logbook). The FWS

ensures that samplers are appropriately trained and available. Samplers collect samples in accordance

with sampling requirements. Samplers also complete field logbooks, data forms, and chain-of-custody

forms (including any shipping paperwork), and enable delivery of the samples to the analytical laboratory.

Pre-job briefings are conducted by FSO in accordance with work management and work release

requirements to evaluate activities and associated hazards by considering the following factors:

Objective of the activities

Individual tasks to be performed, including sample collection

Hazards associated with the planned tasks

Controls applied to mitigate the hazards

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Environment in which the job will be performed

Facility where the job will be performed

Equipment and materials required

2.1.1.9 Quality Assurance

The QA point of contact provides independent oversight and is responsible for addressing QA issues on

the project and overseeing implementation of the project QA requirements. Responsibilities include

reviewing project documents including the QAPjP and participating in QA assessments on sample

collection and analysis activities, as appropriate.

2.1.1.10 Environmental Compliance Officer

The environmental compliance officer provides technical oversight, direction, and acceptance of project

and subcontracted environmental work and develops appropriate mitigation measures with the goal of

minimizing adverse environmental impacts.

2.1.1.11 Health and Safety

The Health and Safety organization is responsible for coordinating industrial safety and health support

within the project as carried out through health and safety plans, job hazard analyses, and other pertinent

safety documents required by federal regulations or internal primary contractor work requirements.

2.1.1.12 Radiological Engineering

Radiological Engineering is responsible for the following:

Providing radiological engineering and project health physics support

Conducting as low as reasonably achievable reviews, exposure and release modeling, and

radiological controls optimization

Identifying radiological hazards and ensuring that appropriate controls are implemented to maintain

worker exposures to hazards at levels as low as reasonably achievable

Interfacing with the project Health and Safety representative and other appropriate personnel as

needed to plan and direct project radiological control technician (RCT) support.

2.1.1.13 Waste Management

Waste Management is responsible for identifying waste management sampling/characterization

requirements to ensure regulatory compliance and for interpreting data to determine waste designations

and profiles. Waste Management communicates policies and practices and ensures project compliance for

storage, transportation, disposal, and waste tracking in a safe and cost-effective manner.

2.1.1.14 Analytical Laboratories

The analytical laboratories accept, manage, prepare, and analyze samples in accordance with established

methods and the requirements of their subcontract, and provide necessary data packages containing

analytical and QC results. Laboratories provide explanations of results to support data review and in

response to resolution of analytical issues. Laboratory quality requirements are consistent with

HASQARD requirements (DOE/RL-96-68). The laboratories are evaluated under the DOE Consolidated

Audit–Accreditation Program (or its successor programs) to DoD/DOE (2019) QSM requirements.

The HASQARD requirements (beyond those within the DoD/DOE QSM) are also evaluated under the

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DOE Consolidated Audit–Accreditation Program. Laboratories are accredited by the Washington State

Department of Ecology (Ecology) for the analyses performed under this SAP.

2.1.1.15 Well Drilling and Well Maintenance

The well drilling and maintenance manager and the well coordination and planning manager are

responsible for the following:

Planning, coordinating, and executing drilling construction

Performing well maintenance activities

Coordinating with the OU technical lead regarding field constraints that could affect sampling design

Coordinating well decommissioning with DOE-RL in accordance with the substantive standards of

WAC 173-160, “Minimum Standards for Construction and Maintenance of Wells”

2.1.2 Quality Objectives and Criteria

The QA objective of this plan is to ensure that the generation of analytical data of known and appropriate

quality is acceptable and useful in order to meet the evaluation requirements identified in this SAP.

Data descriptors known as data quality indicators (DQIs) help determine the acceptability and usefulness

of data to the user. The principal DQIs (precision, accuracy, representativeness, comparability,

completeness, bias, and sensitivity) are defined in Table 2-1 for the purposes of this SAP.

Data quality is defined by the degree of rigor in the acceptance criteria assigned to the DQIs.

The acceptance criteria are typically set by the analytical method itself; however, project-specific

requirements require more stringent acceptance criteria. Section 2.2.1 lists the project-specific acceptance

criteria. Applicable QC guidelines, DQI acceptance criteria, and levels of effort for assessing data

quality are dictated by the intended use of the data and the requirements of the analytical method.

The DQIs are evaluated during a process to assess data usability (Section 2.4.3).

2.1.3 Methods-Based Analysis

Laboratory testing for the analytes discussed in Sections 1.4 and 2.2.1 may include nontarget analytes that

are part of the analytical method (i.e., methods-based reporting). The additional constituents that are part

of the method and reported by the laboratory are for informational purposes. Analytical performance

requirements will be applicable only to the analytes specific to this SAP. Poor QC related to nontarget

analyte results would not result in any required corrective action by the laboratory, except for the

application of proper result qualification flags.

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Table 2-1. Data Quality Indicators

Data Quality Indicator

(QC Element)a Definition

Determination

Methodologies Corrective Actions

Precision

(field duplicates, laboratory

sample duplicates, and matrix

spike duplicates)

Precision measures the agreement among

a set of replicate measurements. Field

precision is assessed through the collection

and analysis of field duplicates. Analytical

precision is estimated by duplicate/replicate

analyses, usually on laboratory control

samples, spiked samples, and/or field

samples. The most commonly used estimates

of precision are the relative standard

deviation and, when only two samples are

available, the relative percent difference.

Use the same analytical instrument to

make repeated analyses on the

same sample.

Use the same method to make

repeated measurements of the same

sample within a single laboratory.

Acquire replicate field samples for

information on sample acquisition,

handling, shipping, storage,

preparation, and analytical processes

and measurements.

If duplicate data do not meet objective:

Evaluate apparent cause (e.g., sample

heterogeneity).

Request reanalysis or remeasurement.

Qualify the data before use.

Accuracy

(laboratory control samples,

matrix spikes, and surrogates)

Accuracy is the closeness of a measured result

to an accepted reference value. Accuracy is

usually measured as a percent recovery.

QC analyses used to measure accuracy include

laboratory control samples, spiked samples,

and surrogates.

Analyze a reference material or

reanalyze a sample to which

a material of known concentration or

amount of pollutant has been added

(a spiked sample).

If recovery does not meet objective:

Qualify the data before use.

Request reanalysis or remeasurement.

Representativeness

(field duplicates)

Sample representativeness expresses the

degree to which data accurately and precisely

represent a characteristic of a population,

parameter variations at a sampling point,

a process condition, or an environmental

condition. It is dependent on the proper design

of the sampling program and will be satisfied

by ensuring that the approved plans were

followed during sampling and analysis.

Evaluate whether measurements

are made and physical samples

collected in such a manner that the

resulting data appropriately reflect the

environment or condition being

measured or studied.

If results are not representative of the

system sampled:

Identify the reason for results not

being representative.

Flag for further review.

Review data for usability.

If data are usable, qualify the data for limited use

and define the portion of the system that the

data represent.

If data are not usable, flag as appropriate.

Redefine sampling and measurement

requirements and protocols.

Resample and reanalyze, as appropriate.

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Determination


Comparability

(field duplicate, field splits,

laboratory control samples,

matrix spikes, and matrix

spike duplicates)

Comparability expresses the degree of

confidence with which one data set can be

compared to another. It is dependent upon the

proper design of the sampling program and

will be satisfied by ensuring that the approved

plans are followed and that proper sampling

and analysis techniques are applied.

Use identical or similar sample

collection and handling methods,

sample preparation and analytical

methods, holding times, and

QA protocols.

If data are not comparable to other data sets:

Identify appropriate changes to data collection

and/or analysis methods.

Identify quantifiable bias, if applicable.

Qualify the data as appropriate.

Resample and/or reanalyze if needed.

Revise sampling/analysis protocols to ensure

future comparability.

Completeness

(no QC element; addressed in

data usability assessment)

Completeness is a measure of the amount of

valid data collected compared to the amount

planned. Measurements are considered valid if

they are unqualified or qualified as estimated

data during validation. Field completeness is

a measure of the number of samples collected

versus the number of samples planned.

Laboratory completeness is a measure of the

number of valid measurements compared to

the total number of measurements planned.

Compare the number of valid

measurements completed (samples

collected or samples analyzed) with

those established by the project’s

quality criteria (data quality objectives

or performance/acceptance criteria).

If data sets do not meet the completeness objective:

Identify appropriate changes to data collection

and/or analysis methods.

Identify quantifiable bias, if applicable.

Resample and/or reanalyze if needed.

Revise sampling/analysis protocols to ensure

future completeness.

Bias

(equipment blanks, field transfer

blanks, full trip blanks, laboratory

control samples, matrix spikes,

and method blanks)

Bias is the systematic or persistent distortion

of a measurement process that causes error in

one direction (e.g., the sample measurement is

consistently lower than the sample’s true

value). Bias can be introduced during

sampling, analysis, and data evaluation.

Analytical bias refers to deviation in one

direction (i.e., high, low, or unknown) of

the measured value from a known

spiked amount.

Sampling bias may be revealed by

analysis of replicate samples.

Analytical bias may be assessed by

comparing a measured value in

a sample of known concentration to

an accepted reference value or by

determining the recovery of a known

amount of contaminant spiked into

a sample (matrix spike).

For sampling bias:

Properly select and use sampling tools.

Institute correct sampling and subsampling

practices to limit preferential selection or loss of

sample media.

Use sample handling practices, including proper

sample preservation, that limit the loss or gain of

constituents to the sample media.

Analytical data that are known to be affected by

either sampling or analytical bias are flagged to

indicate possible bias.

Laboratories that are known to generate biased

data for a specific analyte are asked to correct

their methods to remove the bias as best as

practicable. Otherwise, samples are sent to other

laboratories for analysis.

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Determination


Sensitivity

(method detection limit,

practical quantitation limit, and

relative percent difference)

Sensitivity is an instrument’s or method’s

minimum concentration that can be reliably

measured (i.e., instrument detection limit or

limit of quantitation).

Determine the minimum

concentration or attribute to be

measured by an instrument

(instrument detection limit) or by

a laboratory (limit of quantitation).

The lower limit of quantitationb is the

lowest level that can be routinely

quantified and reported by

a laboratory.

If detection limits do not meet objective:

Request reanalysis or remeasurement using

methods or analytical conditions that will meet

required detection or limit of quantitation.

Qualify/reject the data before use.

Note: Based on SW-846, Test Methods for Evaluating Solid Waste: Physical/Chemical Methods (current update).

a. Acceptance criteria for QC elements are provided in Table 2-5.

b. For purposes of this sampling and analysis plan, the lower limit of quantitation is interchangeable with the practical quantitation limit.

QA = quality assurance

QC = quality control

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2.1.4 Special Training/Certification

Workers receive a level of training that is commensurate with their responsibility for collecting and

transporting samples and that is compliant with applicable U.S. Department of Energy (DOE) orders and

government regulations. The FWS, in coordination with line management, will ensure that special

training requirements for field personnel are met.

Training has been instituted by the contractor management team to meet training and qualification

programs that satisfy multiple training drivers imposed by applicable DOE, Code of Federal Regulations,

and Washington Administrative Code requirements.

Training records are maintained for each employee in an electronic training record database.

The contractor’s training organization maintains the training records system. Line management confirms

that an employee’s training is appropriate and up to date prior to performing work under this SAP.

2.1.5 Documents and Records

The OU project manager (or designee) is responsible for ensuring that the current version of the SAP is

being used and for providing any updates to field personnel. Version control is maintained by the

administrative document control process. Table 2-2 defines the types of changes that may impact the

sampling and the associated approvals, notifications, and documentation requirements.

Table 2-2. Change Control for Sampling Projects

Type of Changea Action Documentation

Minor field change: Changes

that have no adverse effect on

the technical adequacy of the

sampling activity or the

work schedule.

The field personnel recognizing the

need for a field change will consult with

the OU project manager (or designee)

prior to implementing the field change.

Minor field changes will be documented in

the field logbook. The logbook entry will

include the field change, the reason for the

field change, and the names and titles of

those approving the field change.

Minor change: Changes to

approved plans that do not

affect the overall intent of the

plan or schedule.

The OU project manager will inform

DOE-RL and the lead regulatory agency

of the change. EPA determines that

there is no need to revise the document.

Documentation of this change approval

would be in project manager’s

meeting minutes or comparable Tri-Party

Agreement change notice.b

Revision necessary: The lead

regulatory agency determines

that changes to approved plans

require revision to document.

If it is anticipated that a revision is

necessary, the OU project manager will

inform DOE-RL and the lead regulatory

agency. EPA determines that the change

requires revision to the document.

Formal revision of the sampling

document.

References:

DOE/RL-96-68, Hanford Analytical Services Quality Assurance Requirements Document.

Ecology et al., 1989a, Hanford Federal Facility Agreement and Consent Order.

Ecology et al, 1989b, Hanford Federal Facility Agreement and Consent Order Action Plan.

a. Consistent with DOE/RL-96-68 and with Sections 9.3 and 12.4 of Tri-Party Agreement Action Plan (Ecology et al., 1989b).

b. Section 9.3 of the Tri-Party Agreement Action Plan (EPA et al., 1989b) defines the minimum elements of a change notice.

DOE-RL = U.S. Department of Energy, Richland Operations Office

EPA = U.S. Environmental Protection Agency

OU = operable unit

Tri-Party Agreement = Hanford Federal Facility Agreement and Consent Order

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Regarding minor field changes, the OU technical lead (in coordination with the Soil and Groundwater

Remediation Project [S&GRP] subject matter expert) will approve deviations from the SAP that do not

have an adverse effect on the technical integrity or adequacy of the sampling activity. Examples of minor

field changes are as follows:

During groundwater sampling, most groundwater samples will be pumped, although use of another

method may be authorized by the OU technical lead.

The sample depths provided in this SAP are estimated based on known characterization data

and geology collected from nearby wells. For this reason, adjustments to the sample depths are

anticipated. The sample depths may be altered during drilling in consultation with the

OU technical lead.

During split-spoon sampling, if insufficient material is recovered or the split spoon is overdriven, then

(when feasible) a second split spoon will be collected prior to advancing the borehole. If there is

not enough sample volume recovered during split-spoon sampling, laboratory-approved minimum

sample volumes will be used to run all required sample analyses. If it is not possible to collect

sufficient sample volume and perform all analyses, then DOE-RL will be consulted to concur on

the path forward.

Groundwater samples may not be collected before a minimum of three well casing volumes have

been purged and water chemistry (e.g., temperature, pH, and conductivity) has stabilized within

10% variance over three consecutive measurements unless approved by the OU technical lead.

Note that one borehole volume is acceptable if water chemistry (e.g., temperature, pH, and

conductivity) has stabilized within 10% variance over three consecutive measurements for the

depth-discrete groundwater samples collected during drilling.

Regarding minor changes, the OU technical lead (in coordination with the S&GRP subject matter expert)

will consult with DOE-RL and the lead regulatory agency when deviations from the SAP do not affect the

overall intent of the plan. Examples of minor changes include the following:

Changing the type of sample being collected. For example, collecting continuous grab samples

instead of continuous cores.

Selecting a different well construction material and/or well design.

Changing to a different drilling method.

The OU technical lead (in coordination with the S&GRP subject matter expert) will inform DOE-RL and

EPA of deviations from the SAP that affect the overall intent and schedule may require revision to the

approved plan.

Logbooks are required to document field sampling activities. The logbook must be identified with

a unique project name and number. Only authorized individuals may make entries into the logbooks.

Logbooks will be controlled in accordance with internal work requirements and processes. Data forms are

also required for field activities and will be controlled in accordance with internal work requirements

and processes.

The FWS and SMR are responsible for ensuring that the field instructions are maintained and aligned

with revisions or approved changes to the SAP. SMR will ensure that deviations from the SAP

(i.e., minor field changes, as documented in Table 2-2) are reflected in revised field sampling documents

for the samplers and the analytical laboratory. All other changes need to be documented by the

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OU technical lead through Tri-Party Agreement change notice or an update to the SAP. The FWS will

ensure that deviations from the SAP or problems encountered in the field are documented appropriately

(e.g., in the field logbook).

The OU project manager, FWS, or designee is responsible for communicating field corrective

action requirements and ensuring that immediate corrective actions are applied to field activities.

The OU project manager is also responsible for ensuring that project files are appropriately set up and

maintained. The project files will contain project records or references to their storage locations. Project

files may include the following information:

Operational records and logbooks

Data forms

Global positioning system data (a copy will be provided to SMR)

Inspection or assessment reports and corrective action reports

Field summary reports

Interim progress reports

Final reports

Photographs

The following records are managed and maintained by SMR personnel:

Completed field sampling logbooks

Field drilling and analytical data

Groundwater sample reports and field sample reports

Completed chain-of-custody forms

Sample receipt records

Laboratory data packages

Analytical data verification and validation reports

Analytical data “case file purges” (i.e., raw data purged from laboratory files) provided by the

offsite analytical laboratories

Convenience copies of laboratory analytical results are maintained in the HEIS database. Records may be

stored in either electronic (e.g., in the managed records area of the Integrated Document Management

System) or hardcopy format (e.g., DOE Records Holding Area). Documentation and records, regardless

of medium or format, are controlled in accordance with internal work requirements and processes that

ensure accuracy and retrievability of stored records. Records required by the Tri-Party Agreement

(Ecology et al., 1989a) will be managed in accordance with Tri-Party Agreement requirements.

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2.2 Data Generation and Acquisition

This section addresses data generation and acquisition to ensure that the project’s methods for sampling

measurement and analysis, data collection or generation, data handling, and QC activities are appropriate

and documented. Requirements for instrument calibration and maintenance, supply inspections, and data

management are also addressed.

2.2.1 Analytical Methods Requirements

Table 2-3 provides information regarding analytical method requirements for samples collected. Updated

EPA methods and nationally recognized standard methods may be substituted for the analytical methods

identified in Table 2-3 in order to follow any changed requirements in method updates. The new method

must achieve project DQOs as well as or better than the replaced method.

Table 2-3. Performance Requirements for Sample Analysis

Constituent

CAS

Numbera

MCL or WAC

Requirement

(µg/L)b

Analytical

Methodc

PQL

(µg/L)e

General Chemical Parameters

Total organic carbon TOC -- 9060 1,050

Chloride 16887-00-6 250,000 9056, 300.0 400

Nitrate 14797-55-8 10,000 9056, 300.0 250

Nitrite 14797-65-0 1,000 9056, 300.0 250

Sulfate 14808-79-8 250,000 9056, 300.0 1,050

Inorganics – Metals

Manganesed 7439-96-5 50 6020 5.25

Nickeld 7440-02-0 320 6020 21

Volatile Organics

Carbon tetrachloride 56-23-5 3.4 8260 3

Field Measurements

Dissolved oxygen N/A N/A -- N/A

Oxidation reduction

potential N/A N/A -- N/A

pH N/A N/A -- N/A

Specific conductance N/A N/A -- N/A

Temperature N/A N/A -- N/A

Turbidity N/A N/A -- N/A

a. The Hanford Environmental Information System database constituent identification number is used.

b. WAC 173-340-720, “Model Toxics Control Act—Cleanup,” “Groundwater Cleanup Standards,” Method B.

The values listed are equivalent to the action levels listed in Appendix B, Table B-9 of the 200-ZP-1 OU PMP

(DOE/RL-2009-115, Performance Monitoring Plan for the 200-ZP-1 Groundwater Operable Unit

Remedial Action).

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Table 2-3. Performance Requirements for Sample Analysis

Constituent

CAS

Numbera

MCL or WAC

Requirement

(µg/L)b

Analytical

Methodc

PQL

(µg/L)e

c. For EPA Method 300.0, see EPA/600/R-93/100, Methods for the Determination of Inorganic Substances in

Environmental Samples. For four-digit EPA methods, see SW-846, Test Methods for Evaluating Solid Waste:

Physical/Chemical Methods (current update). Equivalent methods may be substituted.

d. Collect filtered and unfiltered samples for metals.

e. The PQLs listed are those included in the 200-ZP-1 OU PMP (DOE/RL-2009-115). The PQLs are specified in

contracts with analytical laboratories. Actual quantitation limits vary by laboratory. Method detection limits for

chemical analyses are three to five times lower than quantitation limits.



MCL = maximum contaminant level


OU = operable unit


PQL = practical quantitation limit

WAC = Washington Administrative Code

2.2.2 Field Analytical Methods

Field screening and survey data will be measured in accordance with HASQARD requirements

(DOE/RL-96-68). Field analytical methods are performed in accordance with manufacturers’ manuals.

Table 2-3 provides the parameters for field measurements.

2.2.3 Quality Control

The QC requirements specified in the SAP must be followed in the field and by the analytical laboratory

to ensure that reliable data are obtained. Field QC samples will be collected to evaluate the potential for

cross-contamination and to provide information pertinent to sampling variability. Laboratory QC samples

estimate the precision, bias, and matrix effects of the analytical data. Field and laboratory QC samples are

summarized in Table 2-4. Acceptance criteria for field and laboratory QC samples are listed in Table 2-5.

Data will be qualified and flagged in the HEIS database, as appropriate.

Table 2-4. QC Samples

Sample Type Primary Characteristics Evaluated Frequency

Field QC

Equipment blank Contamination from nondedicated

sampling equipment As neededa

Full trip blank

Contamination from containers,

preservative reagents, storage, or

transportation

One per 20 sampling events (well tripsb)

Field transfer blank Contamination from sampling site

One per day when VOCs are sampled;

additional field transfer blanks are

collected if VOC samples are acquired on

the same day for multiple laboratories

(wells or other media samples)

Field duplicate samples Reproducibility/sampling precision One per 20 sampling events (well tripsb)

Field split samples Interlaboratory comparability As needed

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Table 2-4. QC Samples

Sample Type Primary Characteristics Evaluated Frequency

Laboratory Batch QCc

Method blanks Laboratory contamination One per analytical batchd

Laboratory sample duplicate Laboratory reproducibility and precision One per analytical batchd

Matrix spikes Matrix effect/laboratory accuracy One per analytical batchd

Matrix spike duplicate Laboratory reproducibility, and method

accuracy and precision One per analytical batchd

Surrogates Recovery/yield for organic compounds Added to each sample and QC

Laboratory control sample Method accuracy One per analytical batchd

a. For portable pumps, equipment blanks are collected one per 20 well trips. Whenever a new type of nondedicated equipment

is used, an equipment blank shall be collected every time sampling occurs until it can be shown that less frequent collection of

equipment blanks is adequate to monitor the decontamination procedure for the nondedicated equipment

b. For groundwater a sample is collected any time a well is accessed for sampling; this is also known as a well trip. Field

duplicates and full trip blanks are run at a frequency of one in 20 well trips (i.e., 5% of the well trips) for all groundwater

monitoring wells sampled within any given month and drilling campaign (for all groundwater monitoring programs).

c. A batch is a group of up to 20 samples which behave similarly with respect to the sampling or testing procedures

being employed and which are processed as a unit. Batching across projects is allowed for similar matrices (e.g., Hanford

Site groundwater).

d. Unless not required by, or different frequency is called out, in laboratory analysis method.


VOC = volatile organic compounds

Table 2-5. Field and Laboratory QC Elements and Acceptance Criteria

Analyte QC Element Acceptance Criteria Corrective Action

General Chemical Parameters

Total organic carbon MB

< MDL

<5% sample concentration Flag with “C”

LCS 80% – 120% recovery Flag with “o”a

DUPb or MS/MSDc ≤20% RPD Review datad

MS/MSDc 75% – 125% recovery Flag with “N”

EB, FTB < MDL

<5% sample concentration Flag with “Q”

Field duplicateb ≤20% RPD Review datad

Inorganics – Ammonia, Anions, and Cyanide

Anions by IC MB

< MDL


LCS 80 – 120% recovery Flag with “o”a



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EB, FTB < MDL




ICP/MS metals MB

< MDL


LCS 80% – 120% recovery Flag with “o”a



EB, FTB < MDL



Volatile Organics

Volatile organics by GC/MS MB

< MDL

<5% sample concentration Flag with “B”

LCS 70% – 130% recovery or

statistically derivede Flag with “o”a


MS/MSDc 70% – 130% recovery Flag with “T”

SUR 70% – 130% recovery Review datad

EB, FTB, FXR < MDL



Note: This table applies only to laboratory analyses, not field measurements.

a. The reporting laboratory will apply the “o” flag with Sample Management and Reporting concurrence.

b. Applies when at least one result is greater than the laboratory practical quantitation limit (chemical analyses) or greater

than five times the minimum detectable activity (radiochemical analyses).

c. Either a DUP or MS/MSD is to be analyzed to determine measurement precision (if there is insufficient sample

volume, an LCS duplicate is analyzed with the acceptance criteria defaulting to the <20% RPD criteria (water) or

<30% RPD criteria (soil).

d. After review, corrective actions corrective actions are determined on a case-by-case basis. Corrective actions may

include a laboratory recheck or flagging the data.

e. Laboratory-determined, statistically derived control limits based on historical data are used here. Control limits are

reported with the data.

DUP = laboratory sample duplicate

EB = equipment blank

FTB = full trip blank

GC/MS = gas chromatography/mass spectrometry

IC = ion chromatography

ICP/MS = inductively coupled plasma/mass spectrometry

MB = method blank

MDL = method detection limit

MS = matrix spike

MSD = matrix spike duplicate


RPD = relative percent difference

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LCS = laboratory control sample SUR = surrogate

Data flags:

B, C = possible laboratory contamination; analyte was detected in the associated MB

N = result may be biased; associated MS result was outside the acceptance limits (all methods except GC/MS)

o = result may be biased; associated LCS result was outside the acceptance limits

Q = problem with associated field QC blank; results were out of limits

T = result may be biased; associated MS result was outside the acceptance limits (GC/MS only)

2.2.3.1 Field Quality Control Samples

Field QC samples are collected to evaluate the potential for cross-contamination and provide information

pertinent to field sampling variability and laboratory performance to help ensure reliable data are

obtained. Field QC samples include field duplicates, field split (SPLIT) samples, and three types of field

blanks (equipment blanks [EBs], field transfer blanks [FXRs], and full trip blanks [FTBs]). Field blanks

are typically prepared using high-purity reagent water.1 The QC sample definitions and their required

frequency for collection are described below:

Field duplicates: Independent samples collected as close as possible to the same time and same

location as the scheduled sample and intended to be identical. Field duplicates are placed in separate

sample containers and analyzed independently. Field duplicates are used to determine precision for

both sampling and laboratory measurements.

Field splits (SPLITs): Two samples collected as close as possible to the same time and same location

and intended to be identical. SPLITs will be stored in separate containers and analyzed by different

laboratories for the same analytes. SPLITs are interlaboratory comparison samples used to evaluate

comparability between laboratories.

Equipment blanks (EBs): High-purity water passed through or poured over decontaminated

sampling equipment identical to the sample set collected and placed in sample containers, as

identified on the sample authorization form. The EB sample bottles are placed into storage containers

with samples from the associated sampling event and are analyzed for the same constituents as

samples from the sampling event. EBs are used to evaluate decontamination process effectiveness;

these samples are not required for disposable sampling equipment.

Field transfer blanks (FXRs): Preserved volatile organic analysis sample vials filled with

high-purity water at the sample collection site where volatile organic compound samples are

collected. FXR samples are prepared during sampling to evaluate potential contamination attributable

to field conditions. After collection, FXR sample vials are sealed and placed into the same storage

containers with samples collected the same day for the associated sampling event. FXR samples are

analyzed for volatile organic compounds only.

1 Reagent water is high-purity water that is generally defined as water that has been distilled, deionized, or any

combination of distillation, deionization, reverse osmosis, activated carbon filtration, ion exchange, particulate

filtration, or other polishing techniques (DOE/RL-96-68).

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Full trip blanks (FTBs): Bottles prepared by the sampling team before traveling to the sampling site.

The preserved bottle set is either for volatile organic analysis only or is identical to the set that will be

collected in the field. The bottles are filled with high-purity water and then sealed and transported

(unopened) to the field in the same storage containers used for samples collected that day. Collected

FTBs are typically analyzed for the same constituents as the samples from the associated sampling

event. FTBs are used to evaluate potential sample contamination from the sample bottles,

preservative, handling, storage, and transportation.

2.2.3.2 Laboratory Quality Control Samples

Internal QA/QC programs are maintained by laboratories used by the project. Laboratory QA includes

a comprehensive QC program that includes the use of laboratory control samples (LCSs), laboratory

sample duplicates (DUPs), matrix spikes (MSs), matrix spike duplicates (MSDs), method blanks (MBs),

and surrogates (SURs). These QC analyses are required by EPA methods (e.g., those in SW-846, Test

Methods for Evaluating Solid Waste: Physical/Chemical Methods [current update]) and will-be run at the

frequency specified in the respective references (unless superseded by agreement). The QC checks

outside of control limits are documented in analytical laboratory reports during data usability assessments

(DUAs). Laboratory QC checks and their typical frequencies are listed in Table 2-4. Acceptance criteria

are presented in Table 2-5. Descriptions of the various types of laboratory QC samples are as follows:

Laboratory control sample (LCS): A control matrix (e.g., reagent water) spiked with analytes

representing the target analytes or certified reference material used to evaluate laboratory accuracy.

Laboratory sample duplicate (DUP): An intralaboratory replicate sample that is used to evaluate

the precision of a method in a given sample matrix.

Matrix spike (MS): An aliquot of a sample spiked with a known concentration of target analyte(s).

The MS is used to assess the bias of a method in a given sample matrix. Spiking occurs prior to

sample preparation and analysis.

Matrix spike duplicate (MSD): A replicate spiked aliquot of a sample that is subjected to the entire

sample preparation and analytical process. MSD results are used to determine the bias and precision

of a method in a given sample matrix.

Method blank (MB): An analyte-free matrix to which the same reagents are added in the same

volumes or proportions as used in the sample processing. The MB is carried through the sample

preparation and analytical procedure and is used to quantify contamination resulting from the

analytical process.

Surrogate (SUR): A compound added to every sample in the analysis batch (field samples and QC

samples) prior to preparation. SURs are typically similar in chemical composition to the analyte being

determined, but they are not normally encountered. SURs are expected to respond to the preparation

and measurement systems in a manner similar to the analytes of interest. Because SURs are added to

every standard, sample, and QC sample, they are used to evaluate overall method performance in

a given matrix. SURs are used only in organic analyses.

Laboratories are required to analyze samples within the holding times specified in Table 2-6. In some

instances, constituents in the samples not analyzed within holding times may be compromised by

volatilization, decomposition, or by other chemical changes. Data from samples analyzed outside of

holding times are flagged in the HEIS database with an “H.”

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Table 2-6. Holding-Time Guidelines for Laboratory Analytes

Constituent/

Parameter Preservation* Holding Time

General Chemistry Parameters

pH None Analyze immediately

Total organic carbon Store ≤6C, adjust pH to <2 with H2SO4 or HCl 28 days

Inorganics – Anions

Nitrate, nitrite Store ≤6C 48 hours

Chloride, sulfate Store ≤6C 28 days


ICP/MS Adjust pH to <2 with HNO3 6 months

Volatile Organics

GC/MS Store ≤6C; adjust pH to <2 with HCl (optional) 7 days preserved/

14 days unpreserved

Notes:

Holding times and preservation methods are dependent on the constituent and are consistent with

U.S. Environmental Protection Agency guidance and approved analytical methods.

Container types and volumes will be identified on the chain-of-custody form.

This table only applies to laboratory analyses. Depth to water, dissolved oxygen, oxidation-reduction potential,

pH, specific conductance, temperature, and turbidity are not listed because they are measured in the field.

*For preservation identified as stored at <6°C, the sample should be protected against freezing unless it is known

that freezing will not impact the sample integrity.

GC/MS = gas chromatography/mass spectrometry

ICP/MS = inductively coupled plasma/mass spectrometry

2.2.4 Measurement Equipment

Each measuring equipment user is responsible for ensuring that equipment is functioning as expected,

properly handled, and properly calibrated at required frequencies per methods governing control of the

equipment. Onsite environmental instrument testing, inspection, calibration, and maintenance will be

recorded in accordance with approved methods. Field screening instruments will be used, maintained, and

calibrated in accordance with manufacturers’ specifications and other approved methods.

2.2.5 Instrument and Equipment Testing, Inspection, and Maintenance

Collection, measurement, and testing equipment should meet applicable standards (e.g., ASTM

International [formerly the American Society for Testing and Materials]) or have been evaluated as

acceptable and valid in accordance with instrument-specific methods, requirements, and specifications.

Software applications will be acceptance tested prior to use in the field.

Measurement and testing equipment used in the field or laboratory will be subjected to preventive

maintenance measures to minimize downtime. Laboratories must maintain and calibrate their equipment.

Maintenance requirements (e.g., documentation of routine maintenance) will be included in the individual

laboratory and onsite organization’s QA plan or operating protocols, as appropriate. Maintenance of

laboratory instruments will be performed in a manner consistent with applicable HASQARD

requirements (DOE/RL-96-68).

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2.2.6 Instrument/Equipment Calibration and Frequency

Section 3.5 discusses field equipment calibration. Analytical laboratory instruments are calibrated in

accordance with the laboratory’s QA plan and applicable Hanford Site requirements.

2.2.7 Inspection/Acceptance of Supplies and Consumables

Consumables, supplies, and reagents will be reviewed in accordance with requirements and will be

appropriate for their use. Supplies and consumables used in support of sampling and analysis activities are

procured in accordance with internal work requirements and processes. Responsibilities and interfaces

necessary to ensure that items procured/acquired for the contractor meet the specific technical and quality

requirements must be in place. The procurement system ensures that purchased items comply with

applicable procurement specifications. Supplies and consumables are checked and accepted by users prior

to use.

2.2.8 Nondirect Measurements

Data obtained from sources such as computer databases, programs, literature files, and historical

databases will be technically reviewed to the same extent as data generated as part of any sampling and

analysis QA/QC effort. Data used in evaluations will be identified by source.

2.2.9 Data Management

The SMR organization, in coordination with the OU project manager, is responsible for ensuring that

analytical data are appropriately reviewed, managed, and stored in accordance with applicable

programmatic requirements governing data management methods.

Electronic data access, when appropriate, will be through a Hanford Site database (e.g., HEIS). Where

electronic data are not available, hardcopies will be provided in accordance with Section 9.6 of the

Tri-Party Agreement Action Plan (Ecology et al., 1989b).

Laboratory errors are reported to SMR through an established process. For reported laboratory errors,

a sample issue resolution form will be initiated in accordance with applicable methods. This process is

used to document analytical errors and to establish their resolution with the OU project manager.

The sample issue resolution forms become a permanent part of the analytical data package for future

reference and for records management.

2.3 Assessment and Oversight

Assessment and oversight activities address the effectiveness of project implementation and associated

QA/QC activities. The purpose of assessment is to ensure that the QAPjP is implemented as prescribed.

2.3.1 Assessments and Response Actions

Assessments may be performed to verify compliance with the requirements outlined in this SAP, project

field instructions, the QAPjP, methods, and regulatory requirements. Deficiencies identified by these

assessments will be reported in accordance with existing programmatic requirements. The project line

management chain coordinates the corrective actions/deficiency resolutions in accordance with the

QA program, the corrective action management program, and methods associated with these programs.

When appropriate, corrective actions will be taken by the OU project manager (or designee). A DUA may

be performed for the identified SAP activities. The DUA results will be provided to the OU project

manager. No other planned assessments have been identified. If circumstances arise in the field dictating

the need for additional assessments, then additional assessments will be performed.

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Oversight activities in the analytical laboratories, including corrective action management, are conducted

in accordance with the laboratories’ QA plans. SMR oversees offsite analytical laboratories and verifies

that the laboratories are qualified to perform Hanford Site analytical work.

2.3.2 Reports to Management

Program and project management (as appropriate) will be made aware of deficiencies identified by

assessments and oversight. Issues reported by the laboratories are communicated to SMR, which then

initiates a sample issue resolution form. The process is used to document analytical or sample issues and

to establish resolution with the OU project manager. If an assessment finding results in sampling issues

that affect a regulatory requirement, DOE will be informed and the matter will be discussed with the

regulatory agencies.

2.4 Data Review and Usability

This section addresses QA activities that occur after data collection. Implementation of these activities

determines whether the data conform to the specified criteria, thus satisfying the project objectives.

2.4.1 Data Review and Verification

Data review and verification are performed to confirm that sampling and chain-of-custody documentation

are complete. This review includes linking sample numbers to specific sampling locations and reviewing

sample collection dates and sample preparation and analysis dates to assess whether holding times (if any)

have been met. Furthermore, review of QC data is used to determine whether analyses have met the data

quality requirements specified in this SAP.

The criteria for verification include, but are not limited to, review for contractual compliance

(samples were analyzed as requested), use of the correct analytical method, transcription errors, correct

application of dilution factors, appropriate reporting of dry weight versus wet weight, and correct

application of conversion factors. Field QA/QC results will be reviewed to ensure that the results

are usable.

The OU technical lead performs data reviews to help determine if observed changes reflect potential data

errors, which may result in submitting a request for data review on questionable data. The laboratory may

be asked to check calculations or reanalyze the sample. In extreme cases, another sample may be

collected. Results of the request for data review process are used to flag the data appropriately in

the HEIS database and/or to add comments.

2.4.2 Data Validation

Data validation is an independent assessment to ensure data reliability. Analytical data validation provides

a level of assurance that an analyte is present or absent. Validation may also include the following:

Verification of instrument calibrations

Evaluation of analytical results based on MBs

Recovery of various internal standards

Correctness of uncertainty calculations

Correctness of identification and quantification of analytes

The effect of quality deficiencies on data reliability

The contractor follows the data validation process described in EPA-540-R-2017-001, National

Functional Guidelines for Inorganic Superfund Methods Data Review; and EPA-540-R-2017-002,

National Functional Guidelines for Organic Superfund Methods Data Review, adjusted for use with

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SW-846 (current update), HASQARD (DOE/RL-96-68), and radiochemistry methods. The criteria for

data validation are based on a graded approach, using five levels of validation (Levels A through E).

Level A is the lowest level and is the same as verification. Level E is a 100% review of all data

(e.g., calibration data and calculations of representative samples from the data set). Data validation will

be performed to Level C, which is a review of the QC data. Level C validation consists of a review of the

QC data and specifically requires verification of deliverables; requested versus reported analytes; and

qualification of the results based on evaluation of analytical holding times, MB results, MS/MSD results,

SUR recoveries, and duplicate sample results. Level C data validation is generally equivalent to Level 2A

(EPA 540-R-08-005, Guidance for Labeling Externally Validated Laboratory Analytical Data for

Superfund Use). Level C data validation may be performed on at least 5% of the data by matrix and

analyte group under the direction of SMR. “Analyte group” refers to categories such as radionuclides,

volatile chemicals, semivolatiles, metals, and anions. The goal is to include each of the various analyte

groups and matrices during the data validation process. The DOE-RL project lead or OU project manager

may specify a higher percentage of data to be validated or that data validation be performed at

higher levels.

2.4.3 Reconciliation with User Requirements

The purpose of reconciliation with user requirements is to determine if quantitative data are of the correct

type and are of adequate quality and quantity to meet the project data needs. The DUA process is the

scientific and statistical evaluation of previously verified and validated data to determine if information

obtained from environmental data operations are of the right type, quality, and quantity to support their

intended use (usability). The DUA process uses the entirety of the collected data to determine usability

for decision making. If a statistical sampling design was used during field sampling activities, then the

DUA will be performed following guidance in EPA/240/B-06/003, Data Quality Assessment: Statistical

Methods for Practitioners (EPA QA/G-9S). When judgmental (focused) sampling designs are

implemented in the field, DQIs such as precision, accuracy/bias, representativeness, comparability,

completeness, and sensitivity for the specific data sets (individual data packages) will be evaluated in

accordance with EPA/240/R-02/004, Guidance on Environmental Data Verification and Data Validation

(EPA QA/G-8). Data verification and data validation are integral to the statistical data quality assessment

process and the DQI evaluation process. Results of the DUA processes will be used by the OU project

manager to interpret the data and determine if the DQOs for this activity have been met.

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3 Field Sampling Plan

The objective of the field sampling plan is to clearly identify project sampling and analysis activities.

The field sampling plan uses the sampling design identified during the DQO process and identifies

sampling locations, the total number of samples to be collected, the sampling procedures to be

implemented and analyses to be performed.

The optimization study groundwater monitoring requirements have been divided into two phases:

near-term and long-term. The duration of the near-term 200-ZP-1 OU optimization study groundwater

monitoring is defined as the one-year period following suspension of the active biological treatment for

nitrate, which occurred on October 9, 2019 (i.e., FY 2020). The near-term groundwater sampling and

analysis requirements were implemented through TPA-CN-0875 and are not included in this SAP. This

SAP describes field sampling activities for the long-term groundwater monitoring component of the OSP.

Long-term groundwater monitoring for the OSP is defined as beginning in year 2 of the study (FY 2021)

and continuing through the end of year 5 of the study (FY 2024). The OSP includes an option to extend

the study for 2 years if needed (see Section 4.1.3 in the 200-ZP-1 OU OSP [DOE/RL-2019-38]). If the

optimization study is extended, the long-term monitoring timeframe may also be extended and the

monitoring network and analytes updated.

3.1 Sampling Objectives/Design

The sampling design is judgmental. In judgmental sampling, the selection of sampling units (i.e., the

number and location and/or timing of collecting samples) is based on knowledge of the feature or

condition under investigation and on professional judgment. Judgmental sampling is distinguished from

probability-based sampling in that inferences are based on professional judgment, not statistical scientific

theory. Therefore, conclusions about the target population are limited and depend entirely on the validity

and accuracy of professional judgment.

3.2 Sample Locations and Frequency

Development of the optimization study long-term groundwater monitoring well network and sampling

frequency is described in Section 1.3.4. Each new well installed in proximity to the 200-ZP-1 OU carbon

tetrachloride plume during the optimization study timeframe will be evaluated for inclusion in the study

following the same steps. In addition, the long-term groundwater monitoring network and sampling

frequencies identified in this SAP (Table 3-1) will be continually evaluated using the sample results

obtained and products produced using these and other available data (e.g., predictive analyses and

updated contaminant plume maps). Well network and sampling frequency updates will be documented

using the change control process outlined in Table 2-2 and Section 2.1.5 and will be communicated to

SMR for scheduling purposes. The updates will also be appended to this SAP.

Table 3-1. 200-ZP-1 OU Optimization Study Long-Term Groundwater Monitoring Schedule

Well Name

Sampling Frequencya

Analytes FY 2021 FY 2022 FY 2023 FY 2024 FY 2025

299-W10-1 A A A — — Carbon tetrachloride and anionsb

299-W10-14 Q SA SA SA SA Carbon tetrachloride and anionsb

299-W10-27 Q Q Q Q Q Carbon tetrachloride and anionsb

299-W10-29 SA SA SA SA SA Carbon tetrachloride and anionsb

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Well Name

Sampling Frequencya




299-W11-18 Q Q SA SA SA Carbon tetrachloride and anionsb

299-W11-33Q A A A A A Carbon tetrachloride and anionsb

299-W11-43 A A A A A Carbon tetrachloride and anionsb







299-W13-2P SA SA SA SA SA Carbon tetrachloride and anionsb

299-W13-2Q SA SA SA SA SA Carbon tetrachloride and anionsb






299-W15-11 Q SA A A A Carbon tetrachloride and anionsb

299-W15-152 Q Q SA SA SA Carbon tetrachloride, anions,b

manganese, and nickelc

299-W15-17 Q Q Q SA SA Carbon tetrachloride and anionsb





299-W15-49 Q A A A A Carbon tetrachloride and anionsb




299-W15-83 SA SA SA SA SA Carbon tetrachloride, anions,b


299-W15-94 Q Q SA SA SA Carbon tetrachloride and anionsb


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Well Name

Sampling Frequencya




manganese, nickel,c and TOC


manganese, nickel,c and TOC









299-W19-34A A A A A A Carbon tetrachloride and anionsb

299-W19-34B A A A A A Carbon tetrachloride and anionsb




















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Well Name

Sampling Frequencya



299-W5-2P Q SA SA SA SA Carbon tetrachloride and anionsb

299-W5-2Q A SA SA SA SA Carbon tetrachloride and anionsb



299-W6-17 M Q SA SA SA Carbon tetrachloride and anionsb

299-W6-3 Q Q SA A A Carbon tetrachloride and anionsb

299-W6-6 Q Q Q SA A Carbon tetrachloride and anionsb

299-W7-3 SA SA SA SA SA Carbon tetrachloride, anions,b


699-36-61A A A A A A Carbon tetrachloride and anionsb

699-36-70B A A A A A Carbon tetrachloride and anionsb

699-38-61 SA SA SA A A Carbon tetrachloride and anionsb


699-38-70B A A A A A Carbon tetrachloride and anionsb

699-38-70C A A A A A Carbon tetrachloride and anionsb

699-40-65 A A A A A Carbon tetrachloride and anionsb



699-44-70B Q SA SA SA A Carbon tetrachloride and anionsb


699-45-69C SA SA SA SA SA Carbon tetrachloride and anionsb



699-48-77C Q Q Q Q Q Carbon tetrachloride and anionsb

699-49-79 — A A A A Carbon tetrachloride and anionsb

a. Sampling frequencies are defined as follows: A = annual, M = monthly, SA = semiannual, and Q = quarterly.

b. Anions include nitrate, nitrite, chloride, and sulfate.

c. Collect filtered and unfiltered samples for metals.

FY = fiscal year


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3.3 Sampling Methods

Sampling may include, but is not limited to, the following methods:

Field screening measurements

Radiological screening

Borehole sampling

Groundwater sampling

Water-level measurements

Groundwater samples will be collected post-well purging in accordance with the current revision of

applicable operating methods, as described in general in the following discussion. Groundwater samples

are collected after field measurements of purged groundwater have stabilized:

pH: Two consecutive measurements agree within 0.2 pH units,

Temperature: Two consecutive measurements agree within 0.2°C (32.3°F).

Conductivity: Two consecutive measurements agree within 10% of each other.

Turbidity: Less than 5 nephelometric turbidity units (NTUs) prior to sampling (or upon

recommendation of the OU technical lead).

Dissolved oxygen and oxidation-reduction potential also will be measured in the field under this SAP.

Dissolved oxygen and oxidation-reduction potential measurements are not required to be stable prior to

sample collection.

Unless special requirements are requested from the OU technical lead, wells are typically purged using

the equivalent volume as that of three borehole diameters multiplied by the length of the saturated portion

of the well screen. Stable field readings are also required, as specified above. The default pumping rate is

7.6 to 45.4 L/min (2 to 12 gal/min) depending on the pump, although this is not practical at every well.

On occasions when the purge volume is extraordinarily large, wells are purged for a minimum of

one hour and then sampled once stable field readings are obtained.

Field measurements (except for turbidity) are obtained using a flow-through cell. Groundwater is pumped

directly from the well to the flow-through cell. At the beginning of the sampling event, field crews attach

a clean, stainless-steel sampling manifold to the riser discharge. The manifold has two valves and

two ports: one port is used only for purge water, and the other port is used to supply water to the

flow-through cell. Probes are inserted into the flow-through cell to measure pH, temperature,

conductivity, dissolved oxygen, and oxidation-reduction potential. Turbidity is measured by inserting

a sample vial into a turbidimeter. The purge water is discharged to the purge water truck.

Once field measurements have stabilized, the hose supplying water to the flow-through cell is

disconnected and a clean, stainless-steel drop leg is attached for sampling. The flow rate is reduced during

sampling to minimize loss of volatiles (if any) and prevent overfilling the bottles. Sample bottles are filled

in a sequence designed to minimize loss of volatiles (if any). Filtered samples are collected after

collection of the unfiltered samples. For some constituents (e.g., metals), both filtered and unfiltered

samples are collected. If additional samples require filtration (e.g., at turbidity >5 NTUs), an inline,

disposable 0.45 µm filter is used.

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Typically, three traditional types of environmental-grade sampling pumps (i.e., Grundfos, Hydrostar™,

and submersible electrical pumps) are used for groundwater sampling at Hanford Site monitoring wells.

In addition, low-purge-volume, adjustable-rate bladder pumps may be used. Individual pumps are

selected based on the unique characteristics of the well and the sampling requirements.

A small number of wells may not support sample collection via pumping because of low yield or due to

the physical characteristics of the well. In these cases, a grab sample may be obtained. In cases where

there is not sufficient yield, purge water activities are not performed.

Low-purge-volume sampling methodology for collecting groundwater samples is also being implemented

at the Hanford Site. Low-flow purging and sampling uses a low-purge-volume, adjustable-rate bladder

pump with flow rates typically on the order of 0.1 to 0.5 L/min (0.26 to 0.13 gal/min). This methodology

is intended to minimize excessive movement of water from the soil formation into the well. The objective

is to pump in a manner that minimizes stress (drawdown) to the system. Purge volumes for wells using

low-purge bladder pumps are determined on a well-specific basis based on drawdown, pumping rate,

pump and sample line volume, and volume required to obtain stable field conditions prior to

collecting samples.

Preservatives are required for certain types of samples. Preservatives (based on the media type and

analytical methods) are added to the collection bottles before their use in the field. Groundwater samples

may require filtering in the field, as noted on the chain-of-custody form.

To ensure sample and data usability, the sampling associated with this SAP will be performed in

accordance with HASQARD requirements (DOE/RL-96-68) for sample collection, collection equipment,

sample handling, and sample shipment to the laboratory.

Table 2-6 specifies the sample preservation and holding-time requirements for groundwater samples.

These requirements are in accordance with the analytical methods specified in Table 2-3. The container

types, preservatives, and volumes will be identified on the sample authorization form and

chain-of-custody form. This SAP defines a “sample” as a set of filled sample bottles for the purpose of

beginning holding-time restrictions.

Holding times are the maximum periods allowed between sample collection and laboratory analysis,

as summarized in Table 2-6. Exceeding required holding times could result in changes in constituent

concentrations due to volatilization, decomposition, or other chemical alterations. Required

holding times depend on the constituent and are listed in analytical method compilations such as

APHA/AWWA/WEF, Standard Methods For the Examination of Water and Wastewater Compendium

(current revision). Recommended holding times are also provided in HASQARD (DOE/RL-96-68).

3.3.1 Decontamination of Sampling Equipment

Sampling equipment will be decontaminated in accordance with sampling equipment decontamination

methods. To prevent potential sample contamination, care should be taken to use decontaminated

equipment for each specific sampling activity.

Grundfos is a registered trademark of Grundfos Holding A/S Corporation, Bjerringbro, Denmark.

Hydrostar™ is a trademark of Instrumentation Northwest, Redmond, Washington.

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Special care should be taken to avoid the following common ways in which cross-contamination or

background contamination may compromise the samples:

Improperly storing or transporting sampling equipment and sample containers

Contaminating the equipment or sample bottles by setting the equipment/sample bottle on or near

potential contamination sources (e.g., uncovered ground)

Handling bottles or equipment with dirty hands or gloves

Improperly decontaminating equipment before sampling or between sampling events

Decontamination of sampling equipment is performed using high-purity water in each step. In general,

three rinse cycles are performed to decontaminate sampling equipment: a detergent rinse, an acid rinse,

and a water rinse. During the detergent rinse, the equipment is washed in a phosphate-free detergent

solution, followed by rinsing with high-purity water in three sequential containers. After the third

high-purity water rinse, equipment that is stainless steel or glass is rinsed in a 1M nitric acid solution

(pH <2). Equipment is then rinsed with high-purity water in three sequential containers (the high-purity

water rinses following the acid rinse are conducted in separate water containers that are not used for

detergent rinse). Following the final high-purity water rinse, equipment is rinsed in hexane and then

placed on a rack to dry. Dry equipment is loaded into a drying oven, and the oven is set at 50°C (122°F)

for items that are not metal or glass or at 100°C (212°F) for metal or glass. Once reaching temperature,

the equipment is baked for 20 minutes and then cooled. The equipment is then removed from the oven,

and the equipment is wrapped in clean, unused aluminum foil using surgeon’s gloves. The wrapped

equipment is stored in a custody-locked, controlled access area.

To decontaminate sampling pumps that are not permanently installed, the pump cowling is first removed,

washed (if needed) in phosphate-free detergent solution, and then reinstalled on the pump. The pump is

then submerged in phosphate-free detergent solution, and 11.4 L (3 gal) of solution are pumped through

the unit and disposed. Detergent solution is then circulated through the submerged pump in high-purity

water and 30.3 L (8 gal) of high-purity water are pumped through the unit and disposed. The pump is

removed from the high-purity water and the intake and housing are covered with plastic sleeving.

The cleaning is documented on a tag affixed to the pump, which includes the following information:

Date pump cleaned

Pump identification

Comments

Signature of person performing the decontamination

3.3.2 Radiological Field Data

Alpha and beta/gamma data collection in the field will be used as needed to support sampling and

analysis efforts. Radiological screening will be performed by the RCT or other qualified personnel in

accordance with Hanford Site procedures. The RCT will record field measurements, noting the location of

the sample and the elevated instrument reading. Elevated measurements will be relayed for inclusion in

the field activity report or operational records, as applicable.

The following information will be provided to field personnel performing work in support of this SAP:

Instructions to RCTs on the methods required to measure sample activity and media for gamma,

alpha, and/or beta emissions, as appropriate.

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Information regarding the portable radiological field instrumentation including a physical description

of the instruments, radiation and energy response characteristics, calibration/maintenance and

performance testing descriptions, and the application/operation of the instrument. These instruments

are commonly used at the Hanford Site to obtain measurements of removable surface contamination

measurements and direct measurements of the total surface contamination.

Instructions regarding the minimum requirements for documenting radiological controls information

in accordance with 10 CFR 835, “Occupational Radiation Protection.”

Instructions for managing the identification, creation, review, approval, storage, transfer, and retrieval

of radiological information.

The minimum standards and practices necessary for preparing, performing, and retaining

radiological-related information.

The requirements associated with preparing and transporting regulated material.

Daily reports of radiological surveys and measurements collected during conduct of field

investigation activities. Data will be cross-referenced between laboratory analytical data and radiation

measurements to facilitate interpreting the investigation results.

3.3.3 Water Levels

Groundwater levels are measured annually across the Hanford Site to construct water table maps that are

used to determine the direction and rate of groundwater flow in the unconfined aquifer (SGW-38815).

Water levels are also measured in wells that are screened in confined or partially confined aquifers to help

determine horizontal and vertical hydraulic gradients.

Using a calibrated depth measurement tape, the depth to water is also recorded in each well prior to

sampling. When two consecutive measurements are taken that agree within 6 mm (0.24 in.), the final

determined measurement is recorded, along with the date and time for the specific event. The depth to

groundwater is subtracted from the elevation of a reference point (usually the top of the casing) to obtain

the water-level elevation. The top of the casing is a known elevation reference point because it has been

surveyed to local reference data.

3.4 Documentation of Field Activities

Logbooks and data forms are required for sampling field activities and will be used in accordance with

HASQARD requirements (DOE/RL-96-68). A logbook must be identified with a unique project name

and number. Only authorized persons may make entries into logbooks. Logbook entries will be reviewed

by the FWS, cognizant scientist/engineer, or other responsible manager; the review will be documented

with a signature and date. Logbooks will be permanently bound, waterproof, and ruled with sequentially

numbered pages. Pages will not be removed from logbooks for any reason. Entries will be made in

indelible ink. Corrections will be made by marking through the erroneous data with a single line, entering

the correct data, and initialing and dating the changes.

Data forms may be used to collect field information; however, information recorded on data forms must

follow the same requirements as those for logbooks. The data forms must be referenced in the logbooks.

A summary of information to be recorded in logbooks or on the data forms is as follows:

Day and date; time task started; weather conditions; and names, titles, and organizations of personnel

performing the task.

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Purpose of visit to the task area.

Site activities in specific detail (e.g., maps and drawings) or the forms used to record such

information (e.g., soil boring log or well completion log). Also, details of any field tests that were

conducted, as well as reference to any forms that were used, other data records, and methods followed

in conducting the activity.

Details of any field calibrations and surveys that were conducted. Reference any forms that were

used, other data records, and the methods followed in conducting the calibrations and surveys.

Details of any samples collected and the preparation (if any) of SPLITS, DUPs, MSs, or field blanks.

Reference the methods followed for sample collection or preparation; list the location of the sample

collected, sample type, each label or tag numbers, sample identification, sample containers and

volume, preservation method, packaging, chain-of-custody form number, and analytical request form

number pertinent to each sample or sample set; and note the time and the name of the individual to

whom sample custody was transferred.

Time, equipment type, serial or identification number, and methods followed for decontamination and

equipment maintenance performed. Reference the page numbers of any logbook where detailed

information is recorded.

Any equipment failures or breakdowns that occurred, with a brief description of repairs

or replacements

3.4.1 Corrective Actions and Deviations for Sampling Activities

The OU project manager, FWS, appropriate field crew supervisors, and SMR personnel must document

deviations from protocols and any issues pertaining to sample collection, chain-of-custody forms, target

analytes, contaminants, sample transport, or noncompliant monitoring. An example of a deviation would

be samples not collected due to field conditions.

As appropriate, such deviations or issues will be documented (e.g., in the field logbook) in accordance

with internal corrective action methods. The OU project manager, FWS, field crew supervisors, or SMR

personnel will be responsible for communicating field corrective action requirements and ensuring that

corrective actions are applied to field activities as soon as practical.

Changes in sample activities that require notification, approval, and documentation will be performed as

specified in Table 2-2.

3.5 Calibration of Field Equipment

Onsite environmental instruments are calibrated in accordance with manufacturers’ operating instructions,

internal work requirements and processes, and/or field instructions that provide direction for equipment

calibration or verification of accuracy by analytical methods. Calibration records will include the raw

calibration data, identification of the standards used, associated reports, date of analysis, and analyst’s

name or initials. The results from all instrument calibration activities are recorded in accordance with

HASQARD requirements (DOE/RL-96-68).

Field instrumentation calibration and QA checks will be performed as follows:

Prior to initial use of a field analytical measurement system.

At the frequency recommended by the manufacturer or methods, or as required by regulations.

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Upon failure to meet specified QC criteria.

Calibration of radiological field instruments on the Hanford Site is performed by the MSA prime

contractor, as specified by their calibration program.

Daily calibration checks, as required, will be performed and documented for each instrument used.

These checks will be made on standard materials sufficiently like the matrix under consideration for

direct comparison of data. Analysis times will be sufficient to establish detection efficiency

and resolution.

Using standards for calibration that are traceable to a nationally recognized standard agency source or

measurement system. Manufacturers’ recommendations for storage and handling of standards (if any)

will be followed. Expired standards will not be used for calibration.

3.6 Sample Handling

Sample handling and transfer will be in accordance with established methods to preclude loss of identity,

damage, deterioration, and loss of sample. Custody seals or custody tape will be used to verify that

sample integrity has been maintained during sample transport. The custody seal will be inscribed with the

sampler’s initials and date. If, during the chain-of-custody process, it is discovered that the custody tape

has been tampered with or broken on the sample bottle, the sample will be analyzed but the results will

include a flag to indicate that custody was broken. If the custody tape has been tampered with or broken

on the cooler, the sample custodian shall note this on the sample receiving documentation.

A sampling and analytical database is used to track samples from the point of collection through the

laboratory analysis process.

3.6.1 Containers

Samples will be collected (where and when appropriate) in break-resistant containers. The field sample

collection record will indicate the lot number of the bottles used in sample collection. When commercially

pre-cleaned containers are used in the field, the lot identification will be retained for documentation.

Containers will be capped and stored in an environment that minimizes the possibility of sample container

contamination. If contamination of the stored sample containers occurs, corrective actions will be

implemented to prevent reoccurrences. Contaminated sample containers cannot be used for a sampling

event. Container sizes may vary depending on laboratory-specific volumes/requirements for meeting

analytical detection limits. Container types and sample amounts/volumes are identified on the

chain-of-custody form.

If required, the Radiological Control organization will measure the contamination levels and the dose

rates associated with the filled sample containers. This information and other data will be used to

select proper packaging, marking, labeling, and shipping paperwork and to verify that the sample can

be received by the analytical laboratory in accordance with the laboratory’s radioactivity acceptance

criteria. If the dose rate on the outside of a sample container or the curie content exceeds levels acceptable

by an offsite laboratory, the FWS (in consultation with SMR) can send smaller sample volumes to

the laboratory.

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3.6.2 Container Labeling

Each sample is identified by affixing a standardized label or tag to the container. This label or tag will

contain the sample identification number. The label will identify (or provide reference to associate the

sample with) the date and time of collection, preservative used (if applicable), analysis required, and the

collector’s name or initials. Sample labels may be either pre-printed or handwritten in indelible or

waterproof ink.

3.6.3 Sample Custody

Sample custody will be maintained in accordance with existing protocols to ensure that sample integrity

is maintained throughout the analytical process. Chain-of-custody protocols will be followed

throughout sample collection, transfer, analysis, and disposal to ensure that sample integrity is

maintained. A chain-of-custody record will be initiated in the field at the time of sampling and will

accompany each sample or set of samples shipped to any laboratory.

Shipping requirements will determine how sample shipping containers are prepared for shipment.

The analyses requested for each sample will be indicated on the accompanying chain-of-custody form.

Each time the responsibility for sample custody changes, the new and previous custodians will sign the

record and note the date and time. The field sampling team will make a copy of the signed record before

sample shipment and transmit the copy to SMR.

The following minimum information is required on a completed chain-of-custody form:

Project name

Collectors’ names

Unique sample number

Date, time, and location (or traceable reference thereto) of sample collection

Matrix

Preservatives

Chain-of-possession information (i.e., signatures and printed names of each individual involved in the

transfer of sample custody and storage locations, and dates/times of receipt and relinquishment)

Requested analyses (or reference thereto)

Number of sample containers per unique sample identification number

Shipped-to information (i.e., analytical laboratory performing the analysis)

Samplers should note any anomalies with the samples. If anomalies are found, samplers should inform

SMR so special direction for analysis can be provided to the laboratory if deemed necessary.

Sample custody will be maintained at subcontract laboratories in accordance with established procedures.

Upon receipt of samples, subcontract laboratories will notify SMR of any Hanford Site chain-of-custody

issues. Subcontracted laboratories will also notify SMR of any chain-of-custody issues identified within

the laboratory.

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3.6.4 Sample Transportation

Packaging and transportation instructions will comply with applicable transportation regulations and DOE

requirements. Regulations for classifying, describing, packaging, marking, labeling, and transporting

hazardous materials, hazardous substances, and hazardous wastes are enforced by the U.S. Department of

Transportation (DOT) as described in 49 CFR 171, “Transportation,” “General Information, Regulations,

and Definitions,” through 177, “Carriage by Public Highway.”2 Carrier-specific requirements defined in

the current edition of International Air Transportation Association (IATA) Dangerous Goods Regulations

will also be used when preparing sample shipments conveyed by air freight providers.

Samples containing hazardous constituents above regulated amounts will be considered hazardous

material in transportation and will be transported in accordance with DOT/IATA requirements. If the

sample material is known or can be identified, then it will be packaged, marked, labeled, and shipped

according to the specific instructions for that material. Appropriate laboratory notifications will be made,

if necessary, through the SMR project coordinator.

Materials are classified by DOT/IATA as radioactive when the isotope specific activity concentration

and the exempt consignment limits described in 49 CFR 173, “Shippers—General Requirements for

Shipments and Packagings,” are exceeded. Samples will be screened (or relevant historical data will be

used) to determine if these values are exceeded. When screening or historical data indicate that samples

are radioactive, the radioactive samples will be properly classified, described, packaged, marked, labeled,

and transported in accordance with DOT/IATA requirements.

Prior to shipping radioactive samples to the laboratory, the organization responsible for shipping will

notify the laboratory of the approximate number of and radiological levels of the samples. The laboratory

is responsible for ensuring that the applicable license limits are not exceeded. Prior to sample receipt, the

laboratory will provide SMR with written acceptance for the samples with elevated radioactive

contamination or dose.

2 Transportation regulations 49 CFR 174, “Carriage by Rail”; and 49 CFR 176, “Carriage by Vessel,” are not

applicable, as these two transportation methods are not used.

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4 Management of Waste

Waste materials are generated during sample collection, processing, and subsampling activities. Waste

will be managed in accordance with Appendix B of the 200 West P&T O&M plan (DOE/RL-2009-124).

Miscellaneous solid waste that has contacted suspect dangerous waste will be managed as dangerous

waste. Purge water and decontamination fluids will be collected and managed in accordance with

DOE/RL-2009-80, Investigation Derived Waste Purgewater Management Work Plan; and

DOE/RL-2011-41, Hanford Site Strategy for Management of Investigation Derived Waste. Packaging

and labeling during waste storage and transportation will meet the applicable substantive federal and/or

state requirements. Waste materials requiring collection will be placed in containers appropriate for the

material and the receiving facility in accordance with the applicable waste management or waste control

plan and applicable substantive federal and/or state requirements.

Offsite analytical laboratories are responsible for the disposal of unused sample quantities and wastes

from analytical processes.

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5 Health and Safety

DOE established the hazardous waste operations safety and health program pursuant to the

Price-Anderson Amendments Act of 1988 to ensure the safety and health of workers involved in

mixed-waste site activities. The program was developed to comply with the requirements of 10 CFR 851,

“Worker Safety and Health Program,” which incorporates the standards of 29 CFR 1910.120,

“Occupational Safety and Health Standards,” “Hazardous Waste Operations and Emergency Response”;

10 CFR 830, “Nuclear Safety Management”; and 10 CFR 835. The health and safety program defines the

chemical, radiological, and physical hazards and specifies the controls and requirements for daily work

activities on the overall Hanford Site. Personnel training; control of industrial safety and radiological

hazards; personal protective equipment; site control and general emergency response to spills, fire,

accidents, injury, site visitors; and incident reporting are governed by the health and safety program.

Site-specific health and safety plans will be used to supplement the general health and safety program.

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6 Reporting

Interim and final reporting for the 200-ZP-1 OU optimization study is presented in Chapter 9 of the

200-ZP-1 OU OSP (DOE/RL-2019-38). The work performed under this SAP and the results and

information acquired will be presented in multiple reports. The activities detailed in this SAP are intended

to support Task 3 and will be documented as part of Task 4 of the 200-ZP-1 OU optimization study.

During Tasks 1, 2, and 3 of the optimization study, interim reporting of optimization study progress,

annual operational costs, and remedy performance will be incorporated in annual 200 West P&T reports.

During Task 4, a final optimization study report will be prepared to summarize the results of the

optimization study (as detailed in Section 9.2 of DOE/RL-2019-38). In addition, the laboratories will

report sample results in analytical data packages.

The long-term groundwater monitoring network and sampling frequencies for the monitoring wells and

associated analytes identified in this SAP (Table 3-1) will be continually evaluated using the sample

results obtained and products produced using these and other available data (e.g., predictive analyses and

updated contaminant plume maps). Reporting will be periodically as needed (i.e., quarterly or

semiannually) to report on progress, in addition to the annual reporting identified above for Tasks 1, 2,

and 3. Well network and sampling frequency changes or updates will be documented using the change

control process outlined in Table 2-2 and Section 2.1.5 and will be communicated to SMR for

scheduling purposes.

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7 References

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Systems Manual (QSM) for Environmental Laboratories, Version 5.3, U.S. Department of

Defense Data Quality Workgroup and the U.S. Department of Energy Consolidated Audit

Program, Washington, D.C. Available at: https://denix.osd.mil/edqw/documents/manuals/qsm-

version-5-3-final/.

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DOE/RL-96-68, 2014, Hanford Analytical Services Quality Assurance Requirements Document,

Volume 1, Administrative Requirements; Volume 2, Sampling Technical Requirements; Volume 3,

Field Analytical Technical Requirements; and Volume 4, Laboratory Technical Requirements,

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Available at:

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DOE/RL-2007-28, 2008, Feasibility Study Report for the 200-ZP-1 Groundwater Operable Unit, Rev. 0,

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Washington. Available at: https://pdw.hanford.gov/document/0096137.

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Plan, Rev. 1, U.S. Department of Energy, Richland Operations Office, Richland, Washington.

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Remedial Action, Rev. 3, U.S. Department of Energy, Richland Operations Office, Richland,

Washington. Available at: https://pdw.hanford.gov/document/AR-03747.

DOE/RL-2009-124, 200 West Pump and Treat Operations and Maintenance Plan, current revision,

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DOE/RL-2011-41, 2011, Hanford Site Strategy for Management of Investigation Derived Waste, Rev. 0,



DOE/RL-2014-48, 2016, Response Action Report for the 200-PW-1 Operable Unit Soil Vapor Extraction

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DOE/RL-2019-68, 2020, Calendar Year 2019 Annual Summary Report for Pump and Treat Operations in

the Hanford Site Central Plateau Operable Units, Rev. 0, U.S. Department of Energy, Richland

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04159.

ECF-200ZP1-20-0056, Calculations to Support Monitoring Network and Sampling Frequency Planning

for the 200-ZP-1 Groundwater Operable Unit (OU) Optimization Study Period, Rev. 0 (pending),

CH2M HILL Plateau Remediation Company, Richland, Washington.

Ecology, EPA, and DOE, 1989a, Hanford Federal Facility Agreement and Consent Order, 2 vols.,

as amended, Washington State Department of Ecology, U.S. Environmental Protection Agency,

and U.S. Department of Energy, Olympia, Washington. Available at:

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Ecology, EPA, and DOE, 1989b, Hanford Federal Facility Agreement and Consent Order Action Plan,

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Ecology Publication No. 04-03-030, 2004, Guidelines for Preparing Quality Assurance Project Plans for

Environmental Studies, revised December 2016, Washington State Department of Ecology,

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of Environmental Information, U.S. Environmental Protection Agency, Washington, D.C.

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EPA/240/B-06/001, 2006, Guidance on Systematic Planning Using the Data Quality Objectives Process,

EPA QA/G-4, Office of Environmental Information, U.S. Environmental Protection Agency,

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ss.pdf.

EPA/240/B-06/003, 2006, Data Quality Assessment: Statistical Methods for Practitioners,

EPA QA/G-9S, Office of Environmental Information, U.S. Environmental Protection Agency,

Washington, D.C. Available at: https://www.epa.gov/sites/production/files/2015-

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EPA/240/R-02/004, 2002, Guidance on Environmental Data Verification and Data Validation,


Washington, D.C. Available at: https://www.epa.gov/sites/production/files/2015-

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EPA/240/R-02/009, 2002, Guidance for Quality Assurance Project Plans, EPA QA/G-5, Office of

Environmental Information, U.S. Environmental Protection Agency, Washington, D.C.

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EPA 540-R-08-005, 2009, Guidance for Labeling Externally Validated Laboratory Analytical Data for

Superfund Use, OSWER 9200.1-85, Office of Solid Waste and Emergency Response,

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EPA-540-R-2017-001, 2017, National Functional Guidelines for Inorganic Superfund Methods Data

Review, Office of Superfund Remediation and Technology Innovation, U.S. Environmental

Protection Agency, Washington, D.C. Available at:

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01/documents/national_functional_guidelines_for_inorganic_superfund_methods_data_review_0

1302017.pdf.

EPA-540-R-2017-002, 2017, National Functional Guidelines for Organic Superfund Methods Data

Review, Office of Superfund Remediation and Technology Innovation, U.S. Environmental

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072017.pdf.

EPA 542-R-13-008, 2013, Remediation Optimization: Definition, Scope and Approach, Office of Solid

Waste and Emergency Response and Office of Superfund Remediation and Technology

Innovation, U.S. Environmental Protection Agency, Washington, D.C. Available at:


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Samples, Office of Research and Development, U.S. Environmental Protection Agency,

Cincinnati, Ohio. Available at:

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EPA, Ecology, and DOE, 2008, Record of Decision Hanford 200 Area 200-ZP-1 Superfund Site, Benton

County, Washington, U.S. Environmental Protection Agency, Washington State Department of

Ecology, and U.S. Department of Energy, Olympia, Washington. Available at:


IATA, 2019, Dangerous Goods Regulations, 60th Edition, International Air Transport Association,

Montreal, Quebec, Canada.

PNNL-22062, 2012, Abiotic Degradation Rates for Carbon Tetrachloride and Chloroform: Final Report,

RPT-DVZ-AFRI-012, Pacific Northwest National Laboratory, Richland, Washington. Available

at: https://www.pnnl.gov/main/publications/external/technical_reports/PNNL-22062.pdf.

Price-Anderson Amendments Act of 1988, Pub. L. 100-408, Aug. 20, 1988, 102 Stat. 1066, 42 USC 2010,

et seq. Available at: https://www.govinfo.gov/content/pkg/STATUTE-102/pdf/STATUTE-102-

Pg1066.pdf.

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SGW-38815, 2009, Water-Level Monitoring Plan for the Hanford Site Soil and Groundwater

Remediation Project, Rev. 0, CH2M HILL Plateau Remediation Company, Richland,

Washington. Available at: https://pdw.hanford.gov/document/0082378H.

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pending, CH2M HILL Plateau Remediation Company, Richland, Washington.

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SGW-65172-VA, 2020, 200-ZP-1 Optimization Study – Resolution of RL Comments Regarding

Integration of a Comprehensive Remediation Evaluation of Groundwater Plumes and Well

Networks, Rev. 0, CH2M HILL Plateau Remediation Company, Richland, Washington. Available

at: https://pdw.hanford.gov/document/AR-04157.

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the 200-ZP-1 Operable Unit Remedial Action, Revision 2, U.S. Department of Energy, Richland

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Administrative Code, Olympia, Washington. Available at:

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WAC 173-340-720, “Model Toxics Control Act—Cleanup,” “Groundwater Cleanup Standards,”

Washington Administrative Code, Olympia, Washington. Available at:

http://apps.leg.wa.gov/WAC/default.aspx?cite=173-340-720.

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Appendix A

Data Quality Objectives for the 200-ZP-1 Operable Unit

Optimization Study

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Contents

A1 State the Problem .......................................................................................................................... A-1

A2 Identify the Goals of the Study..................................................................................................... A-2

A3 Identify the Information Inputs ................................................................................................... A-5

A3.1 Data Inputs to Resolve Decision Statement #1 ..................................................................... A-9

A3.2 Data Inputs to Resolve Decision Statement #2 ................................................................... A-10






A4 Define the Boundaries of the Study ........................................................................................... A-12

A5 Develop the Analytical Approach and Decision Rules ............................................................. A-12

A6 Specify Performance or Acceptance Criteria ........................................................................... A-16

A6.1 Groundwater Levels ............................................................................................................ A-17

A6.2 Pumping Rates ..................................................................................................................... A-18

A6.3 Contaminant Concentrations ............................................................................................... A-18

A6.4 Other Measured Parameters ................................................................................................ A-19

A6.5 Model Predictions................................................................................................................ A-20

A7 Develop the Plan for Obtaining Data ........................................................................................ A-21

A8 References .................................................................................................................................... A-22

Tables

Table A-1. Analytes for 200-ZP-1 OU Optimization Study Groundwater Monitoring ........................ A-6

Table A-2. Performance Requirements for Groundwater Analysis ...................................................... A-7

Table A-3. Summary of Data Inputs to Resolve DSs ........................................................................... A-8

Table A-4. Decision Rules .................................................................................................................. A-16

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Terms

AA alternative action

COC contaminant of concern

DQO data quality objective

DR decision rule

DS decision statement

F&T fate and transport

FY fiscal year

MNA monitored natural attenuation

O&M operations and maintenance

OSP optimization study plan

OU operable unit

P&T pump and treat

PMP performance monitoring plan

PSQ principal study question

RAO remedial action objective

ROD Record of Decision

Rwie Ringold Formation member of Wooded Island – unit E

SAP sampling and analysis plan

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A Data Quality Objectives

The data quality objectives (DQOs) for the 200-ZP-1 Operable Unit (OU) optimization study, as

established in DOE/RL-2019-38, 200-ZP-1 Operable Unit Optimization Study Plan (hereinafter referred

to as the 200-ZP-1 OU optimization study plan [OSP]), were developed in accordance with

EPA/240/B-06-001, Guidance on Systematic Planning Using the Data Quality Objectives Process

(EPA QA/G-4). The DQO process involves a series of logical steps used to plan for the resource-effective

acquisition of environmental data. The performance and acceptable criteria are determined through

the DQO process, which serves as the basis for designing the plan to collect data of adequate quality

and sufficient quantity to support project goals. The DQO process consists of the following seven

iterative steps:

1. State the problem.

2. Identify the goals of the study.

3. Identify the information inputs.

4. Define the boundaries of the study.

5. Develop the analytic approach and decision rules (DRs).

6. Specify performance or acceptance criteria.

7. Develop the plan for obtaining data.

Each of the steps is further discussed in this appendix.

A1 State the Problem

The first step in the DQO process is to define the problem. For the 200-ZP-1 OU, evaluation of the

selected remedy specified in EPA et al., 2008, Record of Decision Hanford 200 Area 200-ZP-1 Superfund

Site, Benton County, Washington (hereinafter referred to as the 200-ZP-1 OU Record of Decision [ROD])

is the ultimate purpose of data collection for the OU. Data and information obtained during the first

6 years of pump and treat (P&T) remedy implementation in the 200-ZP-1 OU suggest that conditions

within the OU are less favorable for attaining remedial action objectives (RAOs) and cleanup levels for

carbon tetrachloride within the timeframes identified in 200-ZP-1 OU ROD. Main factors contributing to

these conditions include an order-of-magnitude slower abiotic degradation rate and a larger contaminant

extent and mass for carbon tetrachloride relative to the assumptions used in DOE/RL-2007-28, Feasibility

Study Report for the 200-ZP-1 Groundwater Operable Unit. As a result, data is needed to provide

a technical basis showing optimization of the 200-ZP-1 OU P&T remedy performance that increases

carbon tetrachloride treatment capacity and accelerates mass removal in order to determine whether the

cleanup levels can be achieved within the 125-year timeframe specified in the 200-ZP-1 OU ROD.

In addition, biofouling parameter data is required to evaluate whether continued disinfection of injection

wells is warranted.

A significant amount of nitrate in the 200-ZP-1 OU (2,186,276 kg) has been extracted and treated by the

P&T system since the beginning of the remedy operations, and the nitrate plume may have been

sufficiently diminished such that active nitrate treatment is no longer needed to meet the RAOs identified

in the 200-ZP-1 OU ROD (EPA et al., 2008). Therefore, an evaluation of suspending the active biological

treatment component of the 200 West P&T and transitioning to monitored natural attenuation (MNA)

for nitrate is warranted and additional anion data, including nitrate, is required.

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The 200-ZP-1 OU OSP (DOE/RL-2019-38), developed in accordance with U.S. Environmental

Protection Agency (EPA) guidelines (EPA 542-R-13-008, Remediation Optimization: Definition, Scope

and Approach), provides objectives and an overall approach to evaluate changes to the treatment facility

and the well network to increase the treatment capacity for carbon tetrachloride and suspend active

biological treatment of nitrate. Data (e.g., facility operational and effluent data, contaminant mass

extraction data, and contaminant plume behavior data) are needed to meet the OSP objectives and to

support future 200-ZP-1 OU remedy decisions. The data will be incorporated into fate and transport

(F&T) modeling and will be used in remedy performance and optimization evaluations. Analytical data

are needed to refine F&T models to determine whether RAOs for carbon tetrachloride and nitrate may be

achieved under optimization study configurations (e.g., increased extraction rate and increased carbon

tetrachloride treatment capacity).

A2 Identify the Goals of the Study

The second step of the DQO process identifies the key decisions and/or goals that must be addressed

to achieve the final solution. The goal of the 200-ZP-1 OU optimization study sampling and analysis

plan (SAP) (provided in the main text of this document) is to provide data of adequate quality and

sufficient quantity to meet the optimization study objectives, as specified in the 200-ZP-1 OU OSP

(DOE/RL-2019-38), which are intended to support future plume remediation in the Ringold Formation

member of Wooded Island – unit E (Rwie) and to verify MNA transition for nitrate.

The primary objective of the study is to provide a technical basis showing optimization of carbon

tetrachloride remediation that supports consideration of potential future 200-ZP-1 OU remedy

modifications (DOE/RL-2019-38). To accomplish this objective, data will need to be collected to support

the following performance monitoring analyses:

Quantify the increased carbon tetrachloride mass removal rate, as well as the associated plume area

volume and concentration reductions under the optimization study configurations.

Evaluate the effectiveness of carbon tetrachloride plume containment under the optimization

study configurations.

Evaluate injection well performance (e.g., specific injection capacity) under the optimization study

configurations and compare that to pre-optimization study performance.

Compare anticipated remedy performance for carbon tetrachloride under the optimization study

configurations with predicted pre-optimization study performance.

Quantify nitrate plume behavior under the optimization study configurations to confirm that transition

to MNA is appropriate for nitrate.

Confirm that treated effluent quality meets injection criteria (except for nitrate).

Predict whether RAOs are expected to be achieved for all contaminants of concern (COCs) under the

optimization study configurations within the timeframe identified in the 200-ZP-1 OU ROD

(EPA et al., 2008).

Additional data will be collected outside of this SAP to support the following secondary optimization

study objectives:

Estimate the costs of the optimization study configurations to support future remedy decisions.

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Integrate data obtained from the Ringold Formation member of Wooded Island – unit A

characterization efforts, which will be collected in accordance with DOE/RL-2019-23, 200-ZP-1

Operable Unit Ringold Formation A Characterization Sampling and Analysis Plan (hereinafter

referred to as the Ringold A SAP), into the overall evaluation of COC plume behavior under the

optimization study configurations.

The supplemental data gathered under this optimization study SAP (analysis of additional parameters,

increased sample frequency in some wells, etc.) will address the additional data needs not already covered

in DOE/RL-2009-115, Performance Monitoring Plan for the 200-ZP-1 Groundwater Operable Unit

Remedial Action (hereinafter referred to as the 200-ZP-1 OU performance monitoring plan [PMP];

DOE/RL-2009-124, 200 West Pump and Treat Operations and Maintenance Plan (hereinafter referred

to as the 200 West P&T operations and maintenance [O&M] plan); and the Ringold A SAP

(DOE/RL-2019-23). Data collected under the PMP, the O&M plan, and the Ringold A SAP may be

used to support the optimization study.

The principal study questions (PSQs) that the data collection must address, along with alternative

actions (AAs) that may result based on the analysis of the collected data, are as follows:

PSQ #1: Can a technical basis be prepared showing a desired carbon tetrachloride mass removal rate

along with associated plume area and concentration reductions under the optimization study

configurations using existing data collection strategies (DOE/RL-2009-115; DOE/RL-2009-124)?

– AA #1A: Yes. No supplemental data collection is required and the report will be prepared as

required under Task 4 of the 200‑ZP‑1 OU OSP; or

– AA #1B: No. Collect supplemental data to define the optimum carbon tetrachloride mass

removal rate along with associated plume area and concentration reductions and prepare the

report as required under Task 4 of the 200-ZP-1 OU OSP.

PSQ #2: Can a technical basis be prepared that sufficiently evaluates the effectiveness of carbon

tetrachloride plume containment under the optimization study configurations using existing data

collection strategies (DOE/RL-2009-115; DOE/RL-2009-124)?



– AA #2B: No. Collect supplemental data to evaluate the effectiveness of carbon tetrachloride

plume containment and prepare the report as required under Task 4 of the 200-ZP-1 OU OSP.

PSQ #3: Can a technical basis be prepared that evaluates injection well performance (e.g., specific

injection capacity) under the optimization study configurations when compared to pre-optimization

study performance?



– AA #3B: No. Collect supplemental data until a technical basis can be prepared that sufficiently

evaluates injection well performance and prepare the report as required under Task 4 of the

200-ZP-1 OU OSP.

PSQ #4: Can a technical basis be prepared that compares anticipated remedy performance for carbon

tetrachloride under the optimization study configurations with predicted pre-optimization

study performance?

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– AA #4B: No. Collect supplemental data until a technical basis can be prepared that compares

anticipated remedy performance for carbon tetrachloride and prepare the report as required under

Task 4 of the 200-ZP-1 OU OSP.

PSQ #5: Can a technical basis be prepared showing nitrate plume behavior under the optimization

study configurations to confirm that transition to MNA is appropriate for nitrate?



– AA #5B: No. Collect supplemental data until a technical basis can be prepared showing nitrate

plume behavior can transition to MNA and prepare the report required under Task 4 of the

200-ZP-1 OU OSP.

PSQ #6: Can a technical basis be prepared that confirms treated effluent quality meets injection

criteria (except for nitrate)?



– AA #6B: No. Collect supplemental data until a technical basis can be prepared that confirms

treated effluent quality meets injection criteria (except for nitrate) and prepare the report as

required under Task 4 of the 200-ZP-1 OU OSP.

PSQ #7: Can a technical basis be prepared that predicts whether RAOs are expected to be achieved

for all COCs under the optimization study configurations within the timeframe of the 200-ZP-1 OU

ROD (EPA et al., 2008)?



– AA #7B: No. Collect supplemental data until a technical basis can be prepared that predicts

whether RAOs are expected to be achieved for all COCs and prepare the report as required under

Task 4 of the 200-ZP-1 OU OSP.

The resulting decision statements (DSs) are the basis for discussion in the subsequent DQO process steps:

DS #1: Determine if a technical basis can be prepared showing a desired carbon tetrachloride

mass removal rate along with associated plume area and concentration reductions under the

optimization study configurations using existing data collection strategies (DOE/RL‑2019‑115;

DOE/RL-2009‑124); then prepare the report as required under Task 4 of the 200‑ZP‑1 OU OSP; else,

collect supplemental data to define the optimum carbon tetrachloride mass removal rate along with

associated plume area and concentration reductions and prepare the report.

DS #2: Determine if a technical basis can be prepared that sufficiently evaluates the effectiveness of

carbon tetrachloride plume containment under the optimization study configurations using existing

data collection strategies (DOE/RL‑2019‑115; DOE/RL‑2009‑124); then prepare the report as

required under Task 4 of the 200‑ZP‑1 OU OSP; else, collect supplemental data to evaluate the

effectiveness of carbon tetrachloride plume containment and prepare the report.

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DS #3: Determine if a technical basis can be prepared that sufficiently evaluates injection well

performance (e.g., specific injection capacity) under the optimization study configurations when

compared to pre-optimization study performance; then prepare the report as required under Task 4 of

the 200‑ZP‑1 OU OSP; else, collect supplemental data until a technical basis can be prepared that

sufficiently evaluates injection well performance and prepare the report.

DS #4: Determine if a technical basis can be prepared that compares anticipated remedy performance

for carbon tetrachloride under the optimization study configurations with predicted pre-optimization

study performance; then prepare the report as required under Task 4 of the 200‑ZP‑1 OU OSP; else,

collect supplemental data until a technical basis can be prepared that compares anticipated remedy

performance for carbon tetrachloride and prepare the report.

DS #5: Determine if a technical basis can be prepared showing nitrate plume behavior under the

optimization study configurations to confirm that transition to MNA is appropriate for nitrate; then

prepare the report as required under Task 4 of the 200‑ZP‑1 OU OSP; else, collect supplemental data

until a technical basis can be prepared showing nitrate plume behavior can transition to MNA and

prepare the report.

DS #6: Determine if a technical basis can be prepared confirming that treated effluent quality meets

injection criteria (except for nitrate); then prepare the report as required under Task 4 of the

200-ZP-1 OU OSP; else, collect supplemental data until a technical basis can be prepared that

confirms treated effluent quality meets injection criteria (except for nitrate) and prepare the report.

DS #7: Determine if a technical basis can be prepared that predicts whether RAOs are expected to be

achieved for all of the COCs under the optimization study configurations within the timeframe of the

200-ZP-1 OU ROD (EPA et al., 2008); then prepare the report as required under Task 4 of the

200-ZP-1 OU OSP; else, collect supplemental data until a technical basis can be prepared that

predicts whether RAOs are expected to be achieved for all COCs and prepare the report.

A3 Identify the Information Inputs

The third step of the DQO process identifies the data and information that may be needed to resolve

the DSs listed in Section A2. The types and specifications of primary data that are collected are

summarized below:

Contaminant sampling data for the groundwater monitoring network: Contaminant sampling for

the 200-ZP-1 OU optimization study monitoring well network is spatially sufficient to include

possible 200 West Area contaminant sources in its coverage, as well as to delineate the horizontal and

vertical extent of carbon tetrachloride contamination above the cleanup levels. The groundwater

samples will be analyzed for the constituents listed in Table A-1. Table A-1 also summarizes the

groundwater samples that are analyzed for other constituents (which include key biogeochemical and

field parameters) for various data uses. Table A-2 lists the analytical methods and performance

requirements for the COCs and other constituents. Table A-2 also lists the highest allowable practical

quantitation limits for the select 200-ZP-1 OU COCs and other constituents.

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Table A-1. Analytes for 200-ZP-1 OU Optimization Study Groundwater Monitoring

Constituent

CAS

Number Data Use

Contaminants of Concern

Carbon tetrachloride 56-23-5 Delineate carbon tetrachloride plume; optimization study

monitoring

Nitrate-N 14797-55-8 Delineate nitrate plume; optimization study monitoring

Other Constituents

Chloride 16887-00-6 Evaluate chlorinated solvent natural attenuation; optimization

study monitoring

Manganesea 7436-96-5 Evaluate natural attenuation; optimization study monitoring

Nickela 7440-02-0 Evaluate stainless steel corrosion; optimization study monitoring

Nitrite-N 14797-65-0 Evaluate nitrate natural attenuation; optimization study

monitoring

Sulfate 14808-79-8 Evaluate natural attenuation; optimization study monitoring

Total organic carbon TOC Evaluate natural attenuation; optimization study monitoring

Field Screening Parametersb

Dissolved oxygen N/A Evaluate natural attenuation and well purge for sampling

Oxidation-reduction potential N/A Evaluate natural attenuation

pH N/A Evaluate well purge for sampling

Specific conductance N/A Evaluate well purge for sampling

Temperature N/A Evaluate well purge for sampling

Turbidity N/A Evaluate well purge for sampling

Source: Table adapted for optimization study monitoring from Appendix B, Table B-6 in DOE/RL-2009-115, Performance

Monitoring Plan for the 200-ZP-1 Groundwater Operable Unit Remedial Action.

a. Collect filtered and unfiltered samples for metals.

b. Field screening parameters to be collected in accordance with DOE/RL-96-68, Hanford Analytical Services Quality

Assurance Requirements Document, Vol. 3, Field Analytical Technical Requirements.




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Table A-2. Performance Requirements for Groundwater Analysis

CAS

Number Analyte

Survey or

Analytical

Methoda Units

Action

Level PQLb Precisionc,d Accuracyc,d

56-23-5 Carbon tetrachloride

(COC) (OSP) 8260 µg/L 3.4e 3 ≤20% 70-130%

14697-55-8 Nitrate-N (COC) (OSP) 9056 or 300.0 µg/L 10 525 ≤20% 80-120%

14797-65-0 Nitrite-N (TP) (OSP) 9056 or 300.0 µg/L 1 525 ≤20% 80-120%

TOC Total organic carbon

(NAP) (OSP) 9060 µg/L N/A 1,050 ≤20% 80-120%

14808-79-8 Sulfate (NAP) (OSP) 9056 or 300.0 mg/L 250 1.05 ≤20% 80-120%

7439-96-5 Manganese (NAP)

(OSP)f 6020 µg/L 50 10.5 ≤20% 80-120%

7440-02-0 Nickel (SSC) (OSP)f 6020 µg/L 320 21 ≤20% 80-120%

16887-00-6 Chloride (NAP) (OSP) 9056 or 300.0 mg/L 250 0.4 ≤20% 80-120%

Reference: DOE/RL-2019-38, 200-ZP-1 Operable Unit Optimization Study Plan.

Note: Analytical method and practical quantitation limits provided in this table do not represent EPA or Washington State

Department of Ecology requirement but are intended solely as guidance.

a. For EPA Method 300.0, see EPA/600/R-93/100, Methods for the Determination of Inorganic Substances in

Environmental Samples. For EPA Methods 160.1, 310.1, 376.1, and 415.1, see EPA/600/4-79/020, Methods for Chemical

Analysis of Water and Wastes. For four-digit EPA Methods, see SW-846, Test Methods for Evaluating Solid Waste:

Physical/Chemical Methods (current update). For standard methods, see APHA/AWWA/WEF, 2017, Standard Methods for

the Examination of Water and Wastewater.

b. PQLs are specified in contracts with analytical laboratories. Actual quantitation limits vary by laboratory. Method

detection limits for chemical analyses are three to five times lower than quantitation limits.

c. Precision and accuracy requirements are identified in CHPRC-00189, Environmental Quality Assurance Project Plan.

d. Accuracy criteria are the minimum for associated batch laboratory control sample percent recoveries. Laboratories may

use statistically derived control limits. Additional analyte-specific evaluations are also performed for matrix spikes and

surrogates as appropriate to the method. Precision criteria are for batch laboratory replicate matrix spike analyses.

e. DOE will cleanup COCs for the 200-ZP-1 Operable Unit subject to WAC 173-340, “Model Toxics Control Act—

Cleanup” (carbon tetrachloride and trichloroethene), so the excess lifetime cancer risk does not exceed 110-5 at the

conclusion of the remedy. Groundwater standards are applicable or relevant and appropriate requirements that are used in

the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 cleanup process to select

cleanup levels.

f. Collect filtered and unfiltered samples for metals.



DOE = U.S. Department of Energy



NAP = natural attenuation evaluation parameter


PQL = practical quantitation limit

SSC = stainless-steel corrosion evaluation parameter


TP = transformation product

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Hydraulic monitoring network data: The 200-ZP-1 OU optimization study monitoring well

network spatially covers an area larger than the area covered by the P&T extraction and injection

wells. The spatial density of monitoring wells is the greatest in the area bounded by the east and west

injection well lines (Figure 2 in the 200-ZP-1 OU PMP [DOE/RL-2009-115]). The monitoring wells

have sufficient vertical coverage to monitor potentiometric groundwater elevations from the

basalt bedrock to the water table, including confined or semiconfined groundwater conditions,

although the number and density of monitoring locations is higher closer to the water table (i.e., in the

upper unconfined aquifer). Operating extraction wells are not included in the groundwater elevation

monitoring well network, although their data are sometimes used to assist with water -level

interpretations. The hydraulic monitoring data include manually measured groundwater elevations

collected as a synoptic data set (i.e., data that are all collected on the same day, or at least under the

same pumping and recharge conditions) and/or transducer -measured groundwater elevations

collected semicontinuously. Measured groundwater elevations are accurate to the nearest 0.30 cm

(0.01 ft).

Remedial system monitoring data: Extraction and injection well flow rates are measured at each

well on a semicontinuous basis using in-line flow meters accurate to 5% of the pumping rate.

Combined influent and effluent contaminant monitoring samples are collected from the treatment

plant influent and effluent sampling ports while the P&T facility is operating (preferably at design

rates). In addition, extraction well contaminant monitoring samples are collected from each individual

extraction well while the well is pumping (preferably at the design rate). The treatment plant and

extraction well samples are analyzed for the COCs listed in Table 1 of the 200-ZP-1 OU PMP

(DOE/RL-2009-115) and other constituents, and the maximum acceptable detection limits are

equal to or less than the cleanup levels listed in Table 1 of the PMP. The P&T remedial system

data collection efforts are discussed in further detail in the 200 West P&T O&M plan

(DOE/RL-2009-124).

The following sections identify the data inputs needed to resolve each DS presented in Section A2.

Table A-3 summarizes the data inputs.

Table A-3. Summary of Data Inputs to Resolve DSs

Data Input DS #

Data Used Directly in Calculations

Water quality (contaminant) sample results from monitoring wells 1, 2, 3, 4,

and 5

Water quality (contaminant) sample results from extraction wells (collected via the 200 West P&T O&M

plan [DOE/RL-2009-124])

1, 2, 4,

and 5

Injection well flow rates, pressures, and total run times (collected via the 200 West P&T O&M plan

[DOE/RL-2009-124]) 3

Treatment plant influent flow rates (collected via the 200 West P&T O&M plan [DOE/RL-2009-124]) 5

Treatment plant influent water quality (contaminant) sample results (collected via the 200 West P&T

O&M plan [DOE/RL-2009-124]) 5

Treatment plant effluent water quality (contaminant) sample results (collected via the 200 West P&T

O&M plan [DOE/RL-2009-124])

1, 2, 3, 4,

5, and 6

Water levels measured in monitoring wells and groundwater elevation (contour) maps prepared using these

data collected and developed under the 200-ZP-1 OU PMP (DOE/RL-2009-115).

1, 2,

and 5

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Table A-3. Summary of Data Inputs to Resolve DSs

Data Input DS #

Water levels measured in extraction and injection wells (collected via the 200 West P&T O&M plan

[DOE/RL-2009-124])

1, 2,

and 5

Data Used Primarily as Input to the Model

The most current three-dimensional contaminant plume depictions, constructed from the groundwater

contaminant sampling data for each COC and mass recovery data 4

Data Used Directly in Calculations and as Input to the Model

Extraction well and injection well flow rate data (collected via the 200 West P&T O&M plan

[DOE/RL-2009-124])

1, 2, 3, 4,

and 5

Additional Data

Logs of well rehabilitation activities and results 3

Plume dynamics for COCs from water quality data collected and evaluated under the performance

monitoring plan 7

References:





O&M = operations and maintenance

OU = operable unit

P&T = pump and treat


A3.1 Data Inputs to Resolve Decision Statement #1

The following data inputs are required to resolve DS #1, “Determine if a technical basis can be prepared

showing a desired carbon tetrachloride mass removal rate along with associated plume area and

concentration reductions under the optimization study configurations using existing data collection

strategies (DOE/RL‑2009‑115; DOE/RL‑2009‑124); then prepare the report as required under Task 4 of

the 200‑ZP‑1 OU OSP; else, collect supplemental data to define the optimum carbon tetrachloride mass

removal rate along with associated plume area and concentration reductions and prepare the report”:

Water quality sample results from monitoring wells

Water quality sample results from extraction wells collected under the 200 West P&T O&M plan

(DOE/RL-2009-124)

Treatment plant effluent water quality sample results collected under the 200 West P&T O&M plan

Water levels measured in monitoring wells and groundwater elevation (contour) maps prepared using

the data collected and developed under the 200-ZP-1 OU PMP (DOE/RL-2009-115)

Water levels measured in extraction and injection wells collected under the 200 West P&T O&M plan

Extraction and injection well flow rate data collected under the 200 West P&T O&M plan

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that sufficiently evaluates the effectiveness of carbon tetrachloride plume containment under the

optimization study configurations using existing data collection strategies (DOE/RL‑2009‑115;

DOE/RL-2009‑124); then prepare the report as required under Task 4 of the 200‑ZP‑1 OU OSP; else,

collect supplemental data to evaluate the effectiveness of carbon tetrachloride plume containment and

prepare the report”:



(DOE/RL-2009-124)



the data collected and developed under the 200-ZP-1 OU PMP (DOE/RL-2009-115)





that sufficiently evaluates injection well performance (e.g., specific injection capacity) under the

optimization study configurations when compared to pre-optimization study performance; then prepare

the report as required under Task 4 of the 200‑ZP‑1 OU OSP; else, collect supplemental data until a

technical basis can be prepared that sufficiently evaluates injection well performance and prepare the

report”:


Injection well flow rate data, pressures, and total run times collected under the 200 West P&T O&M

plan (DOE/RL-2009-124) and used to calculate specific injection capacity


Extraction and well injection flow rate data collected from the 200 West P&T O&M plan

Logs of well rehabilitation activities and results



that compares anticipated remedy performance for carbon tetrachloride under the optimization study

configurations with predicted pre-optimization study performance; then prepare the report as required

under Task 4 of the 200-ZP-1 OU OSP; else, collect supplemental data until a technical basis can be

prepared that compares anticipated remedy performance for carbon tetrachloride and prepare the report”:


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(DOE/RL-2009-124)



The most current three-dimensional contaminant plume depictions, which are constructed from the

groundwater contaminant sampling data for each COC and mass recovery data



showing nitrate plume behavior under the optimization study configurations to confirm transition to MNA

is appropriate for nitrate; then prepare the report as required under Task 4 of the 200-ZP-1 OU OSP; else,

collect supplemental data until a technical basis can be prepared showing nitrate plume behavior can

transition to MNA and prepare the report”:



(DOE/RL-2009-124)

Treatment plant influent flow rates collected under the 200 West P&T O&M plan

Treatment plant influent water quality sample results collected under the 200 West P&T O&M plan



these data collected and developed under the 200-ZP-1 OU PMP (DOE/RL-2009-115)





that confirms treated effluent quality meets injection criteria (except for nitrate); then prepare the report as

required under Task 4 of the 200-ZP-1 OU OSP; else, collect supplemental data until a technical basis can

be prepared that confirms treated effluent quality meets injection criteria (except for nitrate) and prepare

the report”:


(DOE/RL-2009-124)



that predicts whether RAOs are expected to be achieved for all COCs under the optimization study

configurations within the timeframe of the 200-ZP-1 OU ROD [EPA et al., 2008]; then prepare the report

as required under Task 4 of the 200-ZP-1 OU OSP; else, collect supplemental data until a technical basis

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can be prepared that predicts whether RAOs are expected to be achieved for all of the COCs and write the

report”:

Plume dynamics for COCs from water quality data collected and evaluated under the 200-ZP-1 OU

PMP (DOE/RL-2009-115)

A4 Define the Boundaries of the Study

The fourth step of the DQO process is used to identify the spatial and temporal features pertinent to the

decision-making process. The 200-ZP-1 OU performance monitoring network and other monitoring wells

(200-UP-1 OU; Comprehensive Environmental Response, Compensation, and Liability Act; Atomic

Energy Act of 1954; and other newly installed wells) must be monitored to provide data of adequate

quality and quantity to meet the optimization study objectives, which are intended to support future plume

remediation in the Rwie and to verify transition to MNA for nitrate.

Spatially, this performance monitoring (data collection under this study) covers an area from the western

injection well line to the eastern leading edges of the 200-ZP-1 OU plumes. Elevations range from the top

of the basalt bedrock to the water table.

Temporally, near-term and long-term performance monitoring (data collected under this study) began at

the start of fiscal year (FY) 2020 and will continue until optimization study objectives are achieved,

which is estimated to be 5 to 7 years (based on Hanford Site priority work activities and available funding

each fiscal year). Regional and location flow and transport modeling will consider the full hydrogeologic

system and plume transport, spatially and temporally.

A5 Develop the Analytical Approach and Decision Rules

The fifth step of the DQO process involves developing an analytical approach and DRs that outline how

the performance monitoring data will be used to make decisions regarding the progress of the selected

remedy. The DRs for each DS provide clear requirements that guide the decision-making process.

The first three stages of the decision-making process include five workflow components necessary to

successfully monitor and improve performance and ultimately make decisions before proceeding to the

next stage. These workflow components are summarized as the collection of primary data (monitor); the

analysis of primary data (calculate); the modeling for predicting success and for evaluating potential

changes (predict); the reporting of the monitoring, calculations, and predictions (report); and making

necessary changes to the system to improve remedy performance (optimize). The fourth and final stage of

the decision-making process, attainment demonstration, includes three primary workflow components:

collection of primary data (monitor), analysis of primary data (calculate), and the reporting of the

monitoring and analysis data and the recommended decision (report).

The general approach to resolve DSs and manage the remedy uses a combination of several types of

primary data and associated data analysis, as well as a comparison of data to F&T model predictions.

The approach uses these multiple lines of evidence (not a single metric) in an integrated remedy

performance evaluation. Each primary and derived element of the approach provides essential information

to be used in the decision-making process, but limitations of each element exist and must be considered.

Additionally, integrating each element with other elements is necessary to successfully and efficiently

support the decision-making process. The three fundamental components are defined as follows:

Information: Compiled, reduced, and summarized data collected through measurement and

observation, then processed through specified data-reduction techniques to provide the desired input

to the analysis. Information is always based on measurement and observation.

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Limitation: The analysis of information and the resulting knowledge and understanding contain

inherent uncertainties and limitations. These limitations may constrain the ability to extrapolate the

knowledge or understanding beyond identified spatial or temporal boundaries. Specific uncertainties

will be identified that bound the ability to extrapolate from current conditions.

Integration: Collection of measurements and observations presents the opportunity for integration

with other projects and activities, including data collection performed for other OUs. Conversely,

information and developed knowledge may be shared with other projects through integration

activities. Measurements and observations collected and used through integration activities must be

assessed to ensure that they meet the data quality requirements of the current activity and that their

uncertainty and limitations are understood. Information should be clearly identified as based on either

direct data (i.e., collected under the auspices of this activity) or indirect data (i.e., collected through

an integration activity).

Derived data and simulation elements of the approach are listed below, as well as a description of the

information provided by the element, its limitations, and how it is integrated with other elements to

support remedy performance evaluation and management. While many of the elements described below

are gathered under the 200-ZP-1 OU PMP (DOE/RL-2009-115), some of the information is gathered and

provided from data collection efforts conducted via the 200 West P&T O&M plan (DOE/RL-2009-124)

and the 200-ZP-1 OU OSP (DOE/RL-2019-38).

Monitoring well concentration trends:

– Information: Time series of COC concentration in groundwater at monitoring locations based on

measurement and observation.

– Limitation: Limitations are driven by measurement data quality indicators (i.e., precision,

accuracy, representativeness, completeness, and comparability) for individual

location measurements.

– Integration: Data collection offers opportunity for integration with neighboring OUs

(e.g., 200-UP-1 and 200-BP-5).

Contaminant mass removal over time (plume and individual well):

– Information: Time series of COC concentrations in extracted groundwater and post-treatment

effluent based on measurement and observation for individual locations and then extrapolated via

computation to represent the plume overall (P&T operational data).

– Limitation: The most substantial limitation is the interpolation over distance (horizontal and

vertical) between points of measurement and over time (where measurements are relatively

infrequent) and extrapolation beyond points of measurement when necessary. This is particularly

true under dynamic treatment conditions (e.g., P&T), where measured conditions may be

transient in the short term. Individual measurements are subject to limitations driven by

measurement DQOs (i.e., precision, accuracy, representativeness, completeness,

and comparability).

– Integration: This analysis offers the opportunity for integration in data collection with all

(or any) other OUs providing feedstock to the treatment plant.

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Mass degradation over time (plume and individual well):

– Information: Estimation of COC mass degradation requires information based on measurement

and observation of concentrations in groundwater at monitoring locations, in extracted water, and

in post-treatment effluent water, as well as P&T influent and effluent flow rates (P&T operational

data). This can provide an inference of the degraded mass. Refinement of the inferred degraded

mass requires calculation based on knowledge of biological and abiotic COC decay rates under

site conditions.

– Limitation: Estimation of degradation by difference has inherent uncertainty due to variability in

measurements, uncertainty in estimates of mass in the aquifer, and uncertainties in understanding

of the degradation processes.

– Integration: Mass degradation estimates are largely confined to use by the target OU.

Plume volume changes over time (including selected plume contour depictions):

– Information: Changes in time over three-dimensional spatial distribution of the concentration of

COCs in groundwater at monitoring locations based on measurement and observation and

extrapolated through computational approaches to the overall plume.

– Limitation: The most substantial limitation is in interpolation over distance (horizontal and

vertical) between points of measurement and extrapolation beyond points of measurement where

necessary. This is particularly true under dynamic treatment conditions (e.g., P&T), where

measured conditions may be transient in the short term. In addition, the monitoring location

densities decrease with depth in the target aquifer, which adds uncertainty to the extrapolation

calculations. Individual measurements are subject to limitations driven by measurement DQOs

(i.e., precision, accuracy, representativeness, completeness, and comparability).

– Integration: Data collection offers opportunity for integration with neighboring OUs

(e.g., 200-UP-1 and 200-BP-5).

Hydraulic heads and capture zones (plume and individual well):

– Information: This requires information describing the hydraulic conditions within the aquifer

based on measurement and observation, as well as an understanding of aquifer properties to

extrapolate groundwater movement relative to dynamic well conditions (i.e., extraction and

injection). Additional information includes P&T operational data.

– Limitation: As with plume analyses, head and capture analyses are subject to limitations in data

collection (e.g., accuracy, precision, and representativeness of water-level measurement) and

computational capability (e.g., representativeness of selected aquifer hydraulic properties with

respect to actual site conditions). Extrapolations of individual dynamic well conditions to the

aquifer are frequently uncertain.

– Integration: Water-level data and capture zone analyses are applicable to integration with

neighboring OUs (e.g., 200-UP-1 and 200-BP-5) and integration with Hanford Sitewide

groundwater modeling activities.

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P&T operational data and other institutional data:

– Information: Information assembled primarily from measurement and observation of water

quality and volumetric observations during plant operations. This includes groundwater

extraction rates and locations, process effluent injection rates and locations, water quality

(e.g., COC concentrations and geochemistry) of plant influent and effluent, and processed

information describing individual extraction and injection well performance. Institutional

information includes sitewide decisions regarding future land use, as well as selecting points of

calculation and compliance for the groundwater remedy.

– Limitation: As with other inputs, operational data are subject to uncertainties in measurement

and observation data quality. Most of these data are indirect to the 200-ZP-1 OU PMP

(DOE/RL-2009-115) and will need to be assessed for DQO comparability. Most hydraulic

measurements are collected from dynamic monitoring locations (e.g., extraction and injection

wells) and must be carefully considered for comparability when incorporating into the knowledge

base of the overall aquifer.

– Integration: Operational information is directly integrated with other OUs that supply water to

the treatment plant (e.g., 200-UP-1 and 200-BP-5 OUs).

Model predictions of plume behavior and remedy performance:

– Information: Modeling activities require integrating all of the inputs described above to

refine the model performance and enhance the predictability of the model output. Models must be

assembled to represent the system as accurately as reasonable and refined routinely with inputs

based on measurement and observation. As additional information describing aquifer physical

and hydraulic properties becomes available, the model basis must be refined to incorporate the

new information so the model remains representative and comparable to the system.

– Limitations: Models are inherently subject to uncertainties in inputs and definition of

computational parameters. Modeling tools allow calculation of predicted conditions over wide

physical areas and over long periods of time into the future. The level of uncertainty in model

outputs generally increases with the area (and volume) of the aquifer described and with the

simulation time period. A well-performing model should produce a description of aquifer

conditions over relatively short time periods (e.g., years). Short-period descriptive runs should be

performed regularly to ensure continued model representativeness. If short-term results are

comparable, the level of confidence can increase in the longer-term analyses.

– Integration: Models used for the 200-ZP-1 OU are integral to the overall Central Plateau

modeling effort. Two-way integration is essential to provide OU-specific outputs to neighboring

OUs, as well as using neighboring OU inputs to check and validate the target OU model results.

While some of these elements are evaluated annually, some types of data analysis and modeling

evaluation are more appropriately conducted more frequently. During the 200-ZP-1 OU optimization

study period, trend analyses will be conducted annually, although the new data will be plotted and

compared to trend confidence and prediction intervals following receipt of the data. Significant deviations

from confidence or prediction intervals will be used to initiate more frequent evaluation or data collection.

Similarly, model prediction updates would occur at the same frequency. The approach will also consider

three-dimensional aspects of the plume, especially when evaluating plume configuration and mass

changes over time and determining whether the monitoring network needs to be updated either laterally

or vertically.

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Table A-4 presents the DRs generated from each DS developed.

Table A-4. Decision Rules


1 1

If the data confirm the desired carbon tetrachloride mass removal rate along with associated plume

area and concentration reductions are achieved under the optimization study configurations; then


until a technical basis can define the optimum carbon tetrachloride mass removal rate along with

associated plume area and concentration reductions.

2 2

If the data confirm a technical basis can be prepared that sufficiently evaluates the effectiveness of

carbon tetrachloride plume containment under the optimization study configurations; then prepare the

report as required under Task 4 of the 200‑ZP‑1 OU OSP; else, collect supplemental data until

a technical basis can be prepared that sufficiently evaluates the effectiveness of carbon tetrachloride

plume containment.

3 3

If the data confirm a technical basis can be prepared that sufficiently evaluates injection well

performance (e.g., specific injection capacity) under the optimization study configurations when

compared to pre optimization study performance; then prepare the report as required under Task 4 of

the 200-ZP-1 OU OSP; else, collect supplemental data until a technical basis can prepared that

sufficiently evaluates injection well performance.

4 4

If the data confirm a technical basis can be prepared that compares anticipated remedy performance

for carbon tetrachloride under the optimization study configurations with predicted pre optimization

study performance; then prepare the report as required under Task 4 of the 200-ZP-1 OU OSP; else,

collect supplemental data until a technical basis can be prepared that compares anticipated remedy

performance for carbon tetrachloride.

5 5

If the data confirm a technical basis can be prepared showing nitrate plume behavior under the

optimization study configurations to confirm that transition to MNA is appropriate for nitrate; then


until a technical basis can be prepared showing nitrate plume behavior can transition to MNA.

6 6

If the data support a technical basis confirming that treated effluent quality meets injection criteria

(except for nitrate); then prepare the report as required under Task 4 of the 200‑ZP‑1 OU OSP; else,

collect supplemental data until a technical basis can be prepared that confirms treated effluent quality

meets injection criteria (except for nitrate).

7 7

If the results confirm a technical basis can be prepared that predicts whether RAOs are expected to be

achieved for all of the COCs under the optimization study configurations within the timeframe of the

200‑ZP‑1 OU ROD (EPA et al., 2008); then prepare the report as required under Task 4 of the

200‑ZP‑1 OU OSP; else, continue collect supplemental data until a technical basis can be prepared

that predicts whether RAOs are expected to be achieved for all COCs.

Reference: EPA et al., 2008, Record of Decision Hanford 200 Area 200-ZP-1 Superfund Site, Benton County, Washington.


DR = decision rule



OU = operable unit



ROD = record of decision

A6 Specify Performance or Acceptance Criteria

Analytical performance criteria/requirements will be consistent with those established in the

200-ZP-1 OU PMP (DOE/RL-2009-115) to ensure that data collected under this plan will be consistent

with the data collected under the PMP. Table A-2 lists the analytical performance requirements.

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The sixth step of the DQO process involves deriving the performance or acceptance criteria that the

collected data need to achieve to minimize the possibility of either making erroneous conclusions or

failing to keep uncertainty in estimates to within acceptable levels. Typically, the DR as a statistical

hypothesis test is specified in this section, and the consequences of making incorrect decisions from the

statistical hypothesis test are examined. The sampling design is judgmental and not statistically based.

Decisions regarding remedial action success will be based on the guidelines in OSWER 9283.1-44,

Recommended Approach for Evaluating Completion of Groundwater Restoration Remedial Actions at

a Groundwater Monitoring Well.

More quantitative specifications of data quality are defined and presented as part of the quality assurance

project plan provided in Section B2 in Appendix B of the 200-ZP-1 OU PMP (DOE/RL-2009-115).

The following sections present the potential uncertainties associated with the performance monitoring

data to be collected and the potential impacts of those uncertainties.

A6.1 Groundwater Levels

Groundwater-level data consist of several components:

Depth-to-water measurement from top of casing

Surveyed elevation of the top of casing

Surveyed northing and easting coordinates of the well

Elevation interval in the aquifer at which the depth to water is representative (well screen top and

bottom elevations)

The most critical components of groundwater-level data are the depth-to-water measurement and the top

of casing elevation. Elevations for the top of casing are typically specified to the nearest 0.3 cm (0.01 ft),

and depth-to-water measurements are typically specified to the nearest 0.61 cm (0.02 ft). Errors on the

order of a couple of hundredths of a foot can be significant in situations where small horizontal hydraulic

gradients are expected (e.g., in hydraulic stagnation zones between competing extraction wells) or when

calculating vertical hydraulic gradients. In such sensitive areas, capture zone analyses can result in

significant errors, leading to less-than-expected plume capture or unnecessary overpumping.

Groundwater elevation errors can be detected by preparing a two-dimensional water table map and

looking for irregularities in the elevation contours. Also, a groundwater elevation data set can be

compared to the previously collected data set to look for irregularities. While difficult to detect, these

errors can be managed by designing hydraulic capture zones conservatively with a margin of safety so

small errors in measured groundwater elevations do not lead to less-than-expected plume capture or

unnecessary overpumping.

Ground surface elevations are typically provided to the nearest 0.03 m (0.10 ft) and are used along with

the top and bottom screen depths to calculate the top and bottom screen elevations. Errors up to 1.5 m

(5 ft) in top and bottom screen elevations would likely have little impact on the use of groundwater

elevation data because hydraulic stresses are transmitted fairly easily through the aquifer. Since much

of the well construction data for the 200-ZP-1 OU monitoring wells are historical, screened interval data

from monitoring wells may have the potential for significant uncertainty. However, well screen elevation

errors are likely not a significant concern for groundwater elevation data since the vertical spatial

position of groundwater elevation measurement is typically interpreted as the potentiometric groundwater

elevation at the mid-screen elevation in the well. These mid-screen elevation data points can be used in

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the groundwater flow model by comparing them to simulated heads taken from model grid cell

center elevations.

The surveyed northing and easting coordinates are typically provided to the nearest 0.03 m (0.10 ft).

However, errors of up to 1.5 m (5 ft) in well coordinates should have little impact on any processes or

significant decisions. In addition, well coordinates are relatively easy to verify in the field. Thus, well

coordinate errors are likely not a concern.

A6.2 Pumping Rates

Measured pumping rates collected via the 200 West P&T O&M plan (DOE/RL-2009-124) are used to

monitor system performance and ensure that the system is operating within design specifications.

Pumping rates are also used in model calibration, plume shell calibration, model simulations, and

extraction well contaminant mass removal calculations. Pumping rates should be measured on

a semicontinuous basis using in-line flow meters accurate to 5% of the flow rate.

Extraction well flow rate errors can be detected by comparing the sum of the extraction well pumping

rates to the combined influent flow rate at the treatment plant. Pumping rate errors of a couple of liters per

minute/gallons per minute would have little impact on the simulated capture zone for an extraction well

pumping at 379 L/min (100 gal/min). For mass removal calculations for an extraction well with an

influent carbon tetrachloride concentration of 1,000 µg/L, for every 3.8 L/min (1 gal/min) error in flow

rate, there would be an approximately 2 kg/yr error in calculated contaminant mass extracted. If the

carbon tetrachloride plume is assumed to have a dissolved-phase mass above the cleanup level of

approximately 1,221 kg, then this error is approximately 0.2% of the plume mass. For current Hanford

Site laboratory contracts using Method 8260 in SW-846, Test Methods for Evaluating Solid Waste:

Physical/Chemical Methods (current update), the reported carbon tetrachloride concentrations are to be

accurate to within ±20%. For an extraction well pumping at 379 L/min (100 gal/min) with an influent

carbon tetrachloride concentration of 1,000 µg/L, this error percentage could result in the calculated mass

extracted being under- or over-reported by approximately 40 kg/yr. This is equivalent to a 76 L/min

(20 gal/min) flow rate error for a 379 L/min (100 gal/min) flow rate. Therefore, pumping rate errors of

a couple of liters per minute/gallons per minute should have little impact on any significant decisions.

A6.3 Contaminant Concentrations

Contaminant concentration data consist of several components, including the actual groundwater sample,

subsequent laboratory analysis, and the three-dimensional spatial position from which the sample

originated in the aquifer. Table A-2 lists the performance requirements for laboratory analyses.

Contaminant concentrations from analytical laboratory analyses are needed to construct three-dimensional

contaminant plume depictions, calculate the contaminant mass extracted from the extraction wells, and

ultimately verify that cleanup levels have been achieved. To meet this goal, the analytical method

detection limits should be equal to or less than the cleanup levels.

Failure to set analytical laboratory detection limits equal to or less than the cleanup levels could result in

groundwater contaminant monitoring data of insufficient quality to determine a successful cleanup.

Since three-dimensional contaminant plume depictions are usually constructed with the lowest

concentration isosurface set at the cleanup level, use of analytical laboratory detection limits above the

cleanup levels will result in a lack of data to establish the plume outer boundaries. This will result in

errors in the reported mass and volume statistics, errors in extraction well capture analyses, and errors in

simulated contaminant transport.

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Other types of errors (e.g., random nonrepresentative samples and/or laboratory analyses) should have

limited impact on any significant decisions regarding remedy performance. Typically, if a sample result

seems erroneous and the result is critical (i.e., the result significantly changes the conceptual site model,

indicates loss of capture, or falsely indicates plume cleanup), the sampling is repeated at that location to

verify the result. Significant decisions are generally not based on one sample result. An erroneous sample

result could impact the kriged concentrations in a limited area of a contaminant plume. However,

the plume depictions are usually regenerated annually, so the error would be relatively short-lived.

Horizontal spatial position errors are usually of such a small magnitude that they would have little impact

on any processes or significant decisions. Surveyed northing and easting coordinates are typically

provided to the nearest 0.03 m (0.10 ft). Errors of up to 1.5 m (5 ft) in well coordinates would usually

have little impact. In addition, well coordinates are relatively easy to verify in the field; thus, well

coordinate errors are likely not a concern.

Ground surface elevations are typically provided to the nearest 0.03 m (0.10 ft), which is usually used

along with the top and bottom screen depths to calculate the top and bottom screen elevations. Errors in

top and bottom screen elevations of a couple of feet would likely have little impact on the use of

concentration data. However, contaminant concentrations tend to be highly vertically heterogeneous,

and an error of 3.0 m (10 ft) or more in a screened interval could introduce significant errors in the

three-dimensional contaminant plume depictions. Because much of the well construction data is historical

for the older 200-ZP-1 OU monitoring wells, the potential exists for significant errors in the reported well

screened intervals. Such errors could potentially lead to errors in the three-dimensional contaminant

plume depictions and less-than-expected plume capture.

Another vertical spatial position issue with the 200-ZP-1 OU monitoring wells is that many of the wells

have relatively long screened intervals. The screen length for groundwater monitoring wells typically

ranges from 1.5 to 4.6 m (5 to 20 ft); however, many 200-ZP-1 OU monitoring wells have screen lengths

in excess of 9.1 m (30 ft). The variations in screen length can lead to uncertainties in the vertical position

from which groundwater samples were extracted and can cause high contaminant concentration intervals

to be diluted by less contaminated groundwater from other aquifer intervals. Again, such errors could

potentially lead to errors in the three-dimensional contaminant plume depictions and less-than-expected

plume capture.

Vertical spatial position errors in contaminant concentration sampling data are relatively difficult to

detect and manage. Well construction information for a particular monitoring well should be reviewed if

samples collected from the well are questionable in relation to other upgradient and downgradient

samples. However, the relatively low density of samples usually makes it difficult to detect these types

of errors. In general, the uncertainty in three-dimensional contaminant plume delineation caused by the

sparse sampling network is much greater than all of the other sources of contaminant concentration

uncertainty. This uncertainty is furthered by the relative coarseness of the contaminant transport model

grid and the uncertainty in the model transport parameters. These errors are most often managed by using

professional judgment when evaluating the three-dimensional plume depictions and resulting model

simulations for consistency with the conceptual site model and hydrologic principles, as well as by

questioning any discrepancies.

A6.4 Other Measured Parameters

Table A-1 lists other constituent parameters that are included with laboratory analyses. Evaluating these

parameters may provide a better understanding of natural attenuation conditions and/or reaction pathways

within the reactive zones of the plumes. Measurement errors for these parameters would usually have

little impact on any significant decisions regarding natural attenuation processes.

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Table A-1 also lists the groundwater parameters typically measured in the field at each sampled

monitoring well during each monitoring event. These parameters may be monitored continuously in

a flow-through cell apparatus during monitoring well sampling. Stable readings are an indication that

sufficient purgewater has been withdrawn from a well and that a representative sample of the

groundwater can be collected. These parameters are also important for MNA processes. Field

measurement errors for these parameters would usually have little impact on any significant decisions

regarding natural attenuation processes.

A6.5 Model Predictions

Groundwater flow and contaminant transport models are important tools for simulating hydraulic capture

and predicting whether the remedial goals of 95% mass reduction within 25 years and aquifer cleanup

within 125 years will be achieved. However, uncertainties are associated with the use of the model that

can lead to a sense of false confidence in the accuracy of the model predictions. These uncertainties can

be minimized by using multiple lines of evidence to increase the confidence in model predictions by

ensuring that all available data are used. Some of the available methods are described below.

The ability of the groundwater flow model to simulate hydraulic capture accurately can be evaluated by

(1) comparing simulated hydraulic containment with estimates of hydraulic containment prepared using

other methods (such as geostatistics); and/or (2) using a residual analysis method technique, which

compares the simulated head distribution from the model to the measured groundwater elevations, and

displaying the difference in terms of hydraulic capture. This technique is useful for determining if the

model calibration is adequate and ensures that available data are used to make important decisions

regarding plume capture and remedial system optimization. The residual analysis method technique for

analyzing hydraulic data includes the following steps:

1. Calculate the head residuals between the groundwater elevations measured at the monitoring wells

during the synoptic monitoring event and the simulated heads from the groundwater flow model

using the remedial system extraction and injection rates recorded during the synoptic

monitoring event.

2. Analyze the spatial distribution of model results and the application of head residuals to amend the

model results and produce an estimated potentiometric head distribution that closely approximates

the measured data while retaining the hydraulic insight of the model.

3. Apply the amended flow field to generate estimated remedial system hydraulic capture zones.

Particle tracking should be used to generate the capture zones using both the unadjusted simulated

head field and the residual analysis method-amended head field that more closely matches the actual

hydraulic conditions based on the measured groundwater elevations. Application of the residual analysis

method technique may indicate that the current 200 West Area groundwater flow model is not adequate

to accurately predict plume capture and migration, in which case the model should be recalibrated.

The groundwater elevation data collected during the most recent water-level monitoring event would

provide the calibration targets for model recalibration.

The ability of the groundwater transport model to accurately simulate plume migration depends, in part,

on the accuracy of the starting concentration distribution (three-dimensional plume depiction) and the

contaminant transport parameters used in the model. Additionally, the processes represented in the model

are an approximation for the real transport processes. The three-dimensional plume for each contaminant

will adequately represent the available sampling data at the sampling locations based on the method of

construction (e.g., using an interpolation method such as kriging). The uncertainty involves the areas in

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between the sampling locations and the outer boundaries of the plume depictions. The accuracy of each

three-dimensional plume depiction can be increased by providing additional sampling locations; however,

increasing the number of monitoring wells is expensive. Another method that can be used to reduce this

uncertainty involves using measured extraction well contaminant concentrations as calibration targets for

the contaminant transport model and adjusting each plume contaminant distribution until the simulated

extraction well concentrations and mass recovery rates agree with the measured extraction

well concentrations. Also, the outer plume boundaries (both horizontal and vertical) can be controlled

during kriging by using control points and masking or blanking to ensure that the plume boundaries do

not extend above the water table and, in general, agree with the conceptual site model and professional

judgment. Use of these methods, with appropriate documentation of any assumptions invoked,

ensures that all available lines of evidence are being used to construct the three-dimensional

contaminant distributions.

The contaminant transport parameters used in the model can be evaluated by (1) migrating previously

constructed plume versions forward in time and comparing the simulated contaminant concentrations to

the most recent measured contaminant concentrations at selected monitoring well locations, or (2) using

backward simulation approaches to estimate the origins of contaminant mass that has been recovered at

extraction wells. These evaluations can reduce the uncertainty in the transport parameters controlling the

physical, chemical, and biological processes that influence contaminant F&T, and it may result in changes

to the model parameters that control dispersion, retardation, and biodegradation. These methods ensure

that all available lines of evidence are used to reduce the uncertainty associated with model predictions.

A7 Develop the Plan for Obtaining Data

The seventh step of the DQO process is to develop the sampling and analysis design to generate the

data needed to address the goals for the 200-ZP-1 OU selected remedy. The design for collecting data

for contaminant concentration monitoring, hydraulic monitoring, and flow rate monitoring is

presented in Chapter 3 in the main text of this document, in Appendix B of the 200-ZP-1 OU PMP

(DOE/RL-2009-115), in the 200 West P&T O&M plan (DOE/RL-2009-124), and in the 200-ZP-1 OU

OSP (DOE/RL-2019-38). The design is summarized as follows:

Identify monitoring needs to be conducted through FY 2025 (FY 2020 implemented through TPA-

CN-0875, TPA Change Notice Form, DOE/RL-2009-115, Performance Monitoring Plan for the 200-

ZP-1 Operable Unit Remedial Action, Revision 2). In FY 2025, the need for extending the

optimization study will be determined, and subsequent monitoring will be specified at that time if the

study is extended.

Well location and monitoring for constituents needed to meet all objectives for the 200-ZP-1 OU OSP

(DOE/RL-2019-38).

Monitoring will typically include carbon tetrachloride, nitrate, sulfate, and chloride (near-term and

long-term monitoring).

Biofouling parameters will include manganese, nickel, and total organic carbon for selected wells

(primarily for near-term monitoring).

Detailed monitoring well sample schedule, as presented in the SAP (provided in the main text of

this document).

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A8 References

Atomic Energy Act of 1954, as amended, 42 USC 2011, Pub. L. 83-703, 68 Stat. 919. Available at:

https://www.energy.gov/sites/prod/files/2017/10/f38/Atomic%20Energy%20Act%20of%201954

%20%28AEA%29%20in%20U.S.C..pdf.

APHA/AWWA/WEF, 2017, Standard Methods For the Examination of Water and Wastewater,

23rd Edition, American Public Health Association, American Water Works Association, and

Water Environment Federation, Washington, D.C.

CHPRC-00189, 2019, Environmental Quality Assurance Program Plan, Rev. 16, CH2M HILL Plateau

Remediation Company, Richland, Washington. Available at:


Comprehensive Environmental Response, Compensation, and Liability Act of 1980, 42 USC 9601, et seq.,

Pub. L. 107-377, December 31, 2002. Available at:

https://www.csu.edu/cerc/researchreports/documents/CERCLASummary1980.pdf.

DOE/RL-96-68, 2014, Hanford Analytical Services Quality Assurance Requirements Document,

Volume 3, Field Analytical Technical Requirements; and Volume 4, Laboratory Technical

Requirements, Rev. 4, U.S. Department of Energy, Richland Operations Office, Richland,

Washington. Available at:


DOE/RL-2007-28, 2008, Feasibility Study Report for the 200-ZP-1 Groundwater Operable Unit, Rev. 0,




DOE/RL-2009-115, 2020, Performance Monitoring Plan for the 200-ZP-1 Groundwater Operable Unit

Remedial Action, Rev. 3, U.S. Department of Energy, Richland Operations Office, Richland,


DOE/RL-2009-124, 200 West Pump and Treat Operations and Maintenance Plan, current revision,

U.S. Department of Energy, Richland Operations Office, Richland, Washington.

DOE/RL-2019-23, 2020, 200-ZP-1 Operable Unit Ringold Formation A Characterization Sampling and

Analysis Plan, Rev. 0, U.S. Department of Energy, Richland Operations Office, Richland,


DOE/RL-2019-38, 2019, 200-ZP-1 Operable Unit Optimization Study Plan, Rev. 0, U.S. Department of

Energy, Richland Operations Office, Richland, Washington. Available at:


EPA 542-R-13-008, 2013, Remediation Optimization: Definition, Scope and Approach, Office of Solid

Waste and Emergency Response and Office of Superfund Remediation and Technology

Innovation, U.S. Environmental Protection Agency, Washington, D.C. Available at:


08/documents/optimizationprimer_final_june2013.pdf.

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EPA/240/B-06-001, 2006, Guidance on Systematic Planning Using the Data Quality Objectives Process,


Washington, D.C. Available at:

https://www.epa.gov/sites/production/files/documents/guidance_systematic_planning_dqo_proce

ss.pdf.

EPA/600/4-79/020, 1983, Methods for Chemical Analysis of Water and Wastes, Office of Research and

Development, U.S. Environmental Protection Agency, Washington, D.C. Available at:

http://nepis.epa.gov/Exe/ZyPURL.cgi?Dockey=30000Q10.TXT.

EPA/600/R-93/100, 1993, Methods for the Determination of Inorganic Substances in Environmental

Samples, Office of Research and Development, U.S. Environmental Protection Agency,

Cincinnati, Ohio. Available at:

https://nepis.epa.gov/Exe/ZyPDF.cgi/30002U3P.PDF?Dockey=30002U3P.PDF.

EPA, Ecology, and DOE, 2008, Record of Decision Hanford 200 Area 200-ZP-1 Superfund Site, Benton

County, Washington, U.S. Environmental Protection Agency, Washington State Department of

Ecology, and U.S. Department of Energy, Olympia, Washington. Available at:


OSWER 9283.1-44, 2014, Recommended Approach for Evaluating Completion of Groundwater

Restoration Remedial Actions at a Groundwater Monitoring Well, U.S. Environmental Protection

Agency, Washington, D.C. Available at:

https://nepis.epa.gov/Exe/ZyPURL.cgi?Dockey=P100NB98.TXT.

SW-846, Test Methods for Evaluating Solid Waste: Physical/Chemical Methods, current update, Office

of Solid Waste and Emergency Response, U.S. Environmental Protection Agency,

Washington, D.C. Available at: https://www.epa.gov/hw-sw846.

TPA-CN-0875, 2019, TPA Change Notice Form, DOE/RL-2009-115, Performance Monitoring Plan for

the 200-ZP-1 Operable Unit Remedial Action, Revision 2, U.S. Department of Energy, Richland

Operations Office, Richland, Washington, November 6. Available at:


WAC 173-340, “Model Toxics Control Act—Cleanup,” Washington Administrative Code, Olympia,

Washington. Available at: http://apps.leg.wa.gov/WAC/default.aspx?cite=173-340.

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CHPRC - REVIEW COMMENT RECORD (RCR) 1. Date 2. Review No.

12/16/2020 3. Project No.

Page 1 of 3

A-6004-835 (REV 1)

5. Document Number(s)/Title(s) 6. Program/Project/Building Number 7. Reviewer 8. Organization/Group 9. Location/Phone DOE/RL-2019-76, 200-ZP-1 Operable Unit Optimization Study Sampling and Analysis Plan

Emerald Laija EPA Washington, DC 202.564.2724

17. Comment Submittal Approval 10. Agreement With Indicated Comment Disposition(s) 11. CLOSED

Reviewer/Point of Contact (print and sign) Reviewer/Point of Contact (print and sign)

Date Organization Manager (optional) (print and sign)

Date Date

Author/Originator (print and sign) Author/Originator (print and sign)

12. Item 13a. Comments 13b. Basis

13c. Recommendation

14. Reviewer Concurrence Required

(Y or N) 15. Disposition (provide justification if NOT accepted) 16.

Status

Comment 1 Section 1, page 1-3, lines 12-13

This bullet should be deleted

Accept with modification. The text was revised as follows: “Most nitrate in groundwater is currently present at concentrations that are less than an order of magnitude above the cleanup level. Considering current nitrate concentration trends and assuming there is no continuing source of nitrate, sufficient nitrate may have already been removed from the aquifer (resulting in substantial concentration reductions) to enable a transition to the MNA phase of the remedy that will still allow the nitrate cleanup level to be reached within the timeframe specified in the 200-ZP-1 OU ROD (EPA et al., 2008).” Text similar to that in the bullet associated with the comment appeared in two other places within the document (Section 1.2, page 1-10, lines 14-17, and Section 1.3.1, page 1-17, lines 7-9). A similar update was made to the text in these locations.

Closed


12/16/2020 3. Project No.

Page 2 of 3

A-6004-835 (REV 1)

Comment 2 Section 1.1.3,

page 1-9

Add an objective that states, “Obtain new and existing data to quantify impacts on the behavior of other COCs in ZP-1.” We cannot ignore the other COCs in this optimization effort.

Accept with modification. The evaluation of new data collection and existing data to quantify the impacts of the current optimization efforts on the behavior of other COCs is included in this SAP. Per the objectives of the OSP, PSQ#7 and DS#7 (described in Appendix A) address the data collection for evaluating attainment of RAOs for all COCs. Section A3.7 describes that current data collection efforts under the PMP would be sufficient to prepare a technical basis for this objective. In addition, a comprehensive plume evaluation effort was initiated to occur concurrently with the optimization study to further evaluate additional optimization needs for other COCs and COPCs throughout the Central Plateau. This comprehensive plume evaluation activity is described on page 1-4 of Chapter 1, and text has been added following the bullets in Section 1.1.3 (page 1-9): “The comprehensive evaluation initiated in FY 2020 as a separate activity taking place concurrently with the optimization study will provide a technical assessment of near- and long-term projected plume remediation, COC treatment, and source contaminant requirements for other COCs and contaminants of potential concern (COPCs). The resulting recommendations from this effort will develop the basis for additional remedy optimization actions that will be integrated into necessary CERCLA decision documents and remedy optimization efforts (anticipated to occur in the FY 2021/2022 timeframe) for relevant OUs in the Central Plateau, including 200-ZP-1.”

Closed


12/16/2020 3. Project No.

Page 3 of 3

A-6004-835 (REV 1)

Comment 3 Section 1.2, page 1-10, lines 14-19

The emphasis here fails to acknowledge the other COCs that need to be addressed in ZP-1.

Accept with modification. A new paragraph has been added following line 19 to describe how the other COCs will be addressed. This text states, “Plume dynamics for COCs from water quality data collected and evaluated under the 200-ZP-1 OU PMP (DOE/RL-2009-115) will be used to predict whether RAOs are expected to be achieved for all of the COCs under the optimization study configurations within the timeframe of the 200-ZP-1 ROD (EPA et al., 2008). In addition, a comprehensive evaluation has been initiated to provide a technical assessment of near- and long-term projected plume remediation, COC treatment, and source contaminant requirements for other COCs and COPCs (SGW-65172-VA).”

Closed

Comment 4 Section 2.4.2, page 2-21, lines 17-21

Formatting issue – missing bullets

Accepted. Formatting corrected to add bullets to list.

Closed

Comment 5 Section 3.3, page 3-5, lines 4-7

Formatting issue – missing bullets

Accepted. Formatting corrected to add bullets to list.

Closed