DOE Consolidated Audit Program Kelly Layne What They Do With The Data September 20, 2016 ASP 2016 Workshop

What They Do With The Data Starting with the End in Mind Who is “They”? What was the driver for the sampling event? How did they choose the parameters and reporting/detection limits?

What They Do With The Data Who is “They”? Environmental Remediation Environmental Monitoring Waste Disposition Safeguards and Securities Occupational Worker Protection

What They Do With The Data Environmental Remediation – CERCLA and RCRA Processes CERCLA: Quality Assurance Project Plans, Remedial Action Work Plans RCRA: Characteristically Hazardous Limits Environmental Monitoring – DOE Orders DOE Order 458.1 (Radiation Protection of the Public and the Environment) DOE Order 436.1 (Departmental Sustainability) Environmental Reporting (ex. NESHAP, etc) What was the driver for the sampling event?

What They Do With The Data What was the driver for the sampling event? Waste Disposition Waste Acceptance Criteria U.S. Department of Transportation Shipping Requirements Safeguards and Securities Operational samples – Nuclear Criticality Safety, Sample shipments Occupational Worker Protection DOE Order 440.1 OSHA Job Hazard Analysis

What They Do With The Data How did they choose the parameters and reporting/detection limits? Environmental Remediation Contaminants of Concern Scoping Sessions, Data Quality Objectives Risk Based CERCLA – EPA and State Involvement/Agreement Method dependent Environmental Monitoring Federal and State Regulations (CFRs) - NPDES Permits DOE Orders Flexibility in method

What They Do With The Data How did they choose the parameters and reporting/detection limits? Waste Disposition U.S. Department of Transportation – “Limited Quantity” Treatment and Disposal Facility Waste Acceptance Criteria Mixed or Low-Level Waste Decisions Listed versus Characteristically Hazardous Land Disposal Restrictions Flexibility in method Free release of material Occupational Worker Protection Contaminants of Concern Exposure times Assign PPE

What They Do With The Data What Happens When the Data is Received? Sample and Data Management Checks (verification/validation) All data received? Chains of custody? Sample preservation check? Holding time requirements met? (extraction and analysis) Unit? Is conversion needed? Requested method match? Relative percent difference check on duplicates? Trend Query? Is there an outlier based on historical data (if applicable)?

What They Do With The Data Validation? Independent, third party validation required? Matrix Spike Recovery? Internal Standard Checks? Initial and Continuing Calibration Checks? Blanks? Interference Checks and Corrections?

What They Do With The Data Data Evaluation by User Compare data point against a standard Limit Based – examples Permit Limits (environmental monitoring) Characteristically Hazardous Limits (waste chacterization) Occupational Worker Protection and Safeguards and Securities Extent of Condition Step Out / Step Down sampling (environmental remediation) Statistical Evaluation Risk Based Outlier consideration

What They Do With The Data What Does the User Do with the Evaluated Data – Step 1? Compare data point against a standard Limit Based – examples Permit Limits (environmental monitoring) Characteristically Hazardous Limits (waste chacterization) Occupational Worker Protection and Safeguards and Securities Extent of Condition Step Out / Step Down sampling (environmental remediation) Statistical Evaluation Risk Based Outlier consideration

What They Do With The Data What Does the User Do with the Evaluated Data – Step 2? Report to show compliance with permits, standards, and DOE Orders Conduct additional sampling to determine nature and extent of contamination Provide to Waste Disposal Facilities for treatment and disposal purposes Provide occupational information to employees Determine if further actions are required under CERCLA (ex. Feasibility study, etc). Modeling, RESRAD, etc

Thank You! Questions?