PB99-963109
EPA541-R99-038
1999
EPA Superfund
Record of Decision Amendment:
Hanford Site - 200 Area (USDOE)
Benton County, WA
3/25/1999
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United States Environmental Protection Agency*
Region X /fo**e
1200 Sixth Avenue "**'"<
Seattle, Washington 98101
U.S. Department of Energy
Environmental Restoration Disposal Facility
Hanford Site - 200 Area
Benton County, Washington
Amended Record of Decision
Decision Summary and Responsiveness Summary
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TABLE OF CONTENTS
SECTION
PAGENTJMRF.T;
DECLARATION
Site Name and Location
Statement of Basis and Purpose !
Assessment of the Site i
i
i
ii
DECISION SUMMARY
Introduction
Site History *
Remedy Selected in the ROD 2
Description of the Modified Remedy \
Evaluation of Alternatives
Selected Amended Remedy for the ERDF ! 1
Statutory Determination _
Documentation of Significant Changes ' }g
RESPONSIVENESS SUMMARY
16
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DECLARATION OF THE RECORD OF DECISION
SITE NAME AND LOCATION
U.S. Department of Energy
Environmental Restoration Disposal Facility
Hanford Site - 200 Area
Benton County, Washington
STATEMENT OF BASIS AND PURPOSE
The State of Washington concurs with the ROD Amendment.
ASSESSMENT OF THE SITE
BACKGROUND AND DESCRIPTION OF THE AMENDMENT TO THE REMEDY
An Explanation of Significant Difference (ESD) (EPA etal 199<5Uni-h,.ppnT7T>r>r» - *
leachate as RefoJce Con e™ t H »° * **** WaSte C°deS *"* WOuId otherwi*e apply to the
the ROD Conservation and Recovery Act (RCRA) and Dangerous Waste ARXRs under
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S™n*°m ?6 ^f CUITentlyis transported to the Liquid Waste Processing Facility (LWPF)
mth±200EastAreaoftheHanfordSitefortreatmentand disposal. The Effluent freatine^FacmS
: treatment and disposal facility, along with the Liquid Effluent Retention
nmary facilities that comprise the LWPF. Wastewaters are held in basins
r for treatment at the ETF. Treatment at ETF significantly reduces or
s- Treated wastewaters from the ETF are disposed
byth-PPA ,« ioo^nTO *«*» e subject of a previous delisting petition;
Under 40 CFR §§ 260.20 and 260.22, facilities may petition the EPA to remove their wastes from
i°^1- by 6XClUdinS ^ fr°m ±e lists of hazardous wastes contained in §§
l Pe^oneK^^provide sufficient information to the EPAtoallowthe Agency
7^ t0 ^ 6XClUded d°eS n0t meet ^ °f ^ Criteria ««to which ^ w«ste
r , "f"8 WaSte* fa additi°n' ^ EPA must determine, where there is a reasonable
basis to believe that factors (including additional constituents) other than those for which the waste
»u ,. ; ~ w "w " ^"^<""vua wasic, mat sucn factors ao not warrant retaining
tne waste as a hazardous waste. *
S>n±7? ?*'r P^** of Energy (DOE) submitted the Environmental Restoration
Disposal Facility Leachate Delisting Petition (the Petition). The Petition describes the history of
leachatemanagementatER^
ySS P ^ ±G ^ ^ Petiti°n alS° includes
oocnt, es m """ o c ^d
potential contaimnants of concern anticipated for waste disposal at the facility. Previous leachate
characterization data indicated that constituent concentrations were below delistin- levels which
account for some minimal dilution and attenuation (See Table 1), although a few we^e above actual
^ ??ePOn, on^alth-B^ Levels and Solubilities Used in the Evaluate™
etitions, Submitted under 40 CFR 260.20 and 260.22, May 1996) which do not account
. ., c o no account
for any dilution or attenuation. These data were not subject to full validation and did not evaluate
' ** tfacrefore Serve only M a Preliminary indication of the
g Hh *"*?** Plan attached t0 ** A°o«te«it, was completed in January of
1999 and the validated data package was submitted to EPA. The Agency evaluated the information
^loweraH 7CH f P?OVlded b/ D°E and determined ^ ^ levels of the constituents were well
below the dehsting levels in Table 1 and that management of the leachate as a non hazardous waste
IS±^
The delisting is considered an up-front and conditional delisting for leachate, including leachate that
will be generated in the future operations of the facility. The delisting is conditional because the
. use e
n* co;ce.ntratlonjequire^nts specified in this amendment and in the sampling and
plan attached to this amendment must continue to be satisfied and management of the
** ^^ ^ ^ theleachate management plan, as
Exclusion from management as ahazardous waste is conditioned on the leachate meetin- the limits
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established in this amendment, as demonstrated through a verification sampling program At a
fi^TeT' ^eresuS^mlSbeea^PSes w? *" C°ntammantS °f COncem (COCs)! quSS^for me
1 after each round of sampling. If the leachate achieves compliance wim^e^thirie^els
Z£ ^±S±i ^Se2?CS Wh°!e ^^^ results from the first'year o
r
ro^of theTl , ^1 ^ fmphn§ regUnen- COCs detected at concentrations greater than
rnnl/ ^ 1 mg ^ Wl1 be monitored on ^ routine basis. DOE shall includf addition^
constituents in the routine sampling list after an evaluation of the data, as required by EPA
Addmonally, an evaluation of the waste streams going to the ERDF shaltb^done^SmuaUyt;
accordance with the sampling and analysis plan to assure that the list of COCs adequately addressS
RouZ±1emS^^^
Routine sampling will take place every six months.
DECLARATION
^en
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f°r *e ^^^^ to the Record of Decision for the USDOE Hanford
^^
en
James C. Bali" *
Acting fcfenager, Richland Operations DatC
United States Department of Energy
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Signature sheet for the Amendment to the Record of Decision for the USDOE Hanford
Envffoiunental^Restoration Disposal Facility between the United States Department of Energy and
7
sgional Administrator, Region 10 /
United States Environmental Protection Agency
Date
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Signature shea for the Amendment to the Record of Decision for the USDOE Hanford
?Sal Facmty brtwcen *" United States Department of Energy and
' "ttlconcumnce by "»
*
Program Manager, Nuclear Waste Program
Washington State Department of Ecology
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DECISION SUMMARY
USDOE Environmental Restoration Disposal Facility
Record of Decision Amendment
I- INTRODUrTTmv
°f Decision
Site Name and Location
USDOE Hanford Environmental Restoration Disposal Facility
Hanford Site - 200 Area
Benton County, Washington
Lead and Support Agencies
!^^^ (EPA) The
°f Ener^POE> md *e Washington Department of Ecology (Ecology) bo*
UP fr°f f d conditional delis^§ of the ERDF leachate. Tte three agencies
in the decision and preparation of this document.
Statutory Citation for a ROD
pnn ? u^11 Cnt documents fimdamental changes to the remedy set forth in the 1 995 ERDF
CFR § 300.435P(^)H10n ** d°CUmentation Procedures have ^een followed as specified at 40
Need for the ROD Amendment
This Amendment is necessary because delisting hazardous waste leachate may be a fundamental
±S H° H^F R,OD5eSarding the implementation of RCRA. Once delisted, the leachate
generated and managed under this ROD will no longer be regarded as a hazardous or dangerous
fo^eme^ ^ ^ WasMngtOn Adn^strative Code, WAC 1 73-303 , which are A^SL
Public Involvement
A newspaper notice was placed in the Tri-City Herald on November 1, 1998 announcing the
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availability of the proposed amendment and the start of the public comment period. Approximately
fourteen hundred copies of a fact sheet describing the amendment proposal were mailed out. A
public comment period was held from November 2 through December 1, 1998. No requests were
received for apublic meeting, therefore, no public meeting was held. The proposed amendment was
discussed with the Hanford Advisory Board and the Hanford Advisory Board - Environmental
Restoration Committee at meetings in October 1998. The decision to amend the ROD is based on
the Administrative Record for the ERDF. Locations where the Administrative Record may be found
are listed below.
Administrative Record
Supporting documentation for this amendment is described in the Environmental Restoration
Disposal Facility Leachate Delisting Petition, (DOE/RL-98-47). This document can be found in the
Administrative Record for the ERDF. This ROD Amendment is based on and will become part of
the Administrative Record for the ERDF, as required by 40 CFR § 300.825(a)(2), and will be
available to the public at the following locations:
ADMINISTRATIVE RECORD (Contains all project documents)
U.S. Department of Energy - Richland Operations Office
Administrative Record Center
2440 Stevens Center
Richland, Washington 99352
INFORMATION REPOSITORIES (Contain limited documentation)
University of Washington Gonzaga University, Foley Center
Suzzallo Library E. 502 Boone
Government Publications Room Spokane, Washington 99258
Seattle, Washington 98195
Portland State University DOE Richland Public Reading Room
Branford Price Millar Library Washington State University, Tri-Cities
SW Harrison and Park 100 Sprout Road, Room 101L
Portland, Oregon 97207 Richland, Washington 99352
H. SITE HISTORY
In 1988, the Hanford Site was scored using the EPA's Hazard Ranking System. As a result of the
scoring, the Hanford Site was added to the NPL in July 1989 as four sites (the 1100 Area, the
200 Area, the 300 Area, and the 100 Area). Each of these areas was further divided into operable
units (a grouping of individual waste units based primarily on geographic area and common waste
sources). These operable units contain contamination in the form of hazardous waste,
radioactive/hazardous mixed waste, and other CERCLA hazardous substances.
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^anticipation of the NPL listing, DOE, EPA, andEcology entered into the Hanford Federal Facility
Agreement and Consent OrHsr in MW i oso T^;«. ar^Q<»»«^,* ^+~UK_I i j •, /- .
The agreement also addresses RCRA compliance and permitting.
m- REMEDY SELECTVn IN THE ROD
The major components of the selected remedy implemented as a result of the 1995 ERDF ROD
include the following:
Initial construction and operation of the first two disposal cells. These cells are expected to
provide an approximate waste disposal capacity of one million yd3. The cells are designed
and constructed to RCRA minimum technological requirements (MTRs) (40 CFR Part 264,
Subpart N). The decisions to expand the landfill in the future will be documented by
amending the ERDF ROD or as part of the RODs for the Hanford operable units.
The ERDF site will cover a maximum of 4.1 km2 (1.6 mi2) on the Central Plateau, southeast
of the 200 West Area and southwest of the 200 East Area. The initial construction of the
facility required 165 acres of this area.
The ERDF facility will provide sufficient leachate storage capacity to ensure uninterrupted
operations, and will comply with 40 CFR Part 264, Subpart N. Leachate collected at the
landfill will be managed at the 200 Area Effluent Treatment Facility, located in the 200 East
Area, or other approved facility.
Surface water run-on/run-off will be controlled at the landfill and other areas of the facility
that are potentially contaminated.
Air monitoring will be accomplished by placement at ERDF of real-time air monitors for
radioactive contaminants and air samplers for hazardous and radioactive constituents to
detect any offsite migration of contaminants.
Groundwater monitoring will be performed in accordance with 40 CFR Part 264, Subpart
Appropriate measures to protect facility workers and the public will continue to be employed
during ERDF operations, including contamination control and dust mitigation, and protection
of personnel from industrial hazards presented by ERDF operations. Protective measures
shall comply with applicable requirements found in the Occupational Safety and Health Act
(OSHA), Washington Industrial Safety and Health Act (WISHA), and other safety
regulations or ERDF-specific safety requirements. Energy shall also comply with 40 CFR
§ 300.150.
Waste acceptance criteria have been developed by DOE and approved by the EPA in
accordance with applicable or relevant and appropriate requirements (ARARs),
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risk/performance assessments, ERDF-specific safety documentation, and worker protection
requirements. Operable unit-specific waste disposal and treatment decisions will continue
to be made as part of the remedy selection and cleanup decision process for each operable
unit.
The ERDF landfill will be closed by placing a modified RCRA-compliant closure cover over
the waste. The cover will prevent direct exposure to the waste and will include a vegetated
surface layer of fine-grained soils to retain moisture and encourage evapo-transpiration,
thereby rmmmmng infiltration and vadose zone transport of contaminants to groundwater
The upper 50 cm (20 in.) of the soil cover system will be composed of an admixture of silt
and gravels. This layer is intended to both reduce infiltration through the cover and enhance
the resistance of the cover to burrowing animals and long-term wind erosion. The RCRA-
comphant cover will be modified by providing a total of approximately 15 feet of cover
material to deter intrusion. It is anticipated that additional research into closure covers may
result in site-specific enhancements to RCRA-compliant designs. Prior to cover
construction, closure cover designs will be evaluated and the most appropriate closure cover
design will be selected for construction. Construction of the cover will occur on an
incremental basis, as the trench is expanded. The design will, at a minimum, comply with
applicable RCRA requirements found at 40 CFR Part 264, Subpart N. Basalt from Hanford
Site borrow pits will not be required for construction of the ERDF closure cover.
Institutional controls shall be imposed to restrict public access to ttie landfill
Equipment will be available to transport wastes and operate the ERDF safely. '
Hanford Site infrastructure will be expanded as necessary to support the ERDF
Infrastructure improvements or extensions may include water, sewer, electric power roads
operations facilities, and a chemical and fuel storage area.
A decontamination facility will be constructed consisting of, at a minimum, an impervious
pad with a sump, wash water storage, and secondary containment. Washwater used to
decontaminate site equipment shall be managed in compliance with appropriate
requirements. vv r
The detailed design will be submitted to EPA for approval (with consultation with Ecology)
prior to construction of the ERDF facility. At a minimum, it will be submitted in two
packages to allow for construction hi phases.
An operations plan will be submitted to the EPA for approval (with consultation with
Ecology) prior to operation of the ERDF facility.
Mitigation measures to reduce ecological impacts have been incorporated to satisfy the
Remedial Action Objectives identified in Section 7(4)(i) through 7(4)(v). In addition DOE
commits to the development and implementation of a Mitigation Action Plan in coordination
with the Natural Resource Trustees for additional mitigation measures.
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The Explanation of Significant Differences to the ERDF ROD, issued in July of 1996, authorized
the following changes:
Any Hanford environmental cleanup waste generated as a result of CERCL A or RCRA
cleanup actions (EDW, decontamination and decommissioning wastes, RCRA past-practice
wastes) is eligible for disposal provided it meets the ERDF Waste Acceptance Criteria and
provided that the appropriate CERCLA decision documents are in place. Additionally, non-
process waste (e.g., contaminated soil, debris) generated from closure of inactive RCRA
TSD units may be placed in ERDF provided that the units (1) are within the boundaries of
a CERCLA or RCRA past-practice operable unit, (2) the closure wastes are sufficiently
similar to CERCLA or RCRA past-practice wastes placed in ERDF, (3) the ERDF waste
acceptance criteria are satisfied, and (4) the appropriate CERCLA decision documents are
in place. Revision of the RCRA Permit and closure plans may be required.
The ERDF leachate may be collected and stored at the ERDF for use within the trench, as
appropriate. Appropriate uses are limited to dust suppression and waste compaction. The
leachate must be sampled prior to use to ensure compliance with Land Disposal Restrictions
(LDRs), ERDF waste acceptance criteria, and other health-based limits (whichever is more
restrictive). Leachate in excess of ERDF recycling capacity or acceptable contaminant levels
will be sent to the Effluent Treatment Facility or another approved facility for management.
Changes to the original ROD were addressed in a ROD Amendment issued in September 1997
These changes are explained below.
ERDF Expansion. The ERDF ROD specifies that expansion of the facility would be
authorized as-needed through the ROD amendment process. Based on estimated remediation
waste volumes presented in the ERDF ROD, additional disposal cells were anticipated. Two
additional ERDF cells are being constructed for disposal of Hanford Site remediation waste.
Remediation volume estimates in final and planned cleanup decision documents, prepared
since the ERDF ROD was issued, supported the need for additional capacity. The Phase E
construction is located entirely within the 4.1 km2 (1.6 mi2) area selected for ERDF as
defined in the ERDF ROD. The same RCRA design selected for the existing ERDF
disposal cells is being used for the Phase n cells.
Treatment at ERDF. The selected remedial alternative in existing 100 and 300 Area waste
site remediation RODs is removal, treatment if required, and disposal at ERDF. Treatment
is required if the concentration of contaminants in the waste is above land disposal restriction
standards found in the Federal and State hazardous waste regulations or above the ERDF
waste acceptance criteria. The Amendment provides the option of conducting remediation
waste treatment at ERDF instead of the operable unit, prior to disposal. This option does not
preclude treatment at the operable units. Treatment at ERDF is limited to stabilization and
encapsulation in containers. In addition, all substantive federal and state requirements
governing hazardous waste treatment in containers, such as secondary containment, must be
met as part of treatment at ERDF. The decision whether to perform remediation waste
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treatment, and the specific treatment needed, must be documented as part of the remedy
selection and remedial design process for the operable unit or waste site of origination.
W* DESCRIPTION OF TWF MODIFIED REMEDY
Leachate from the ERDF currently is transported to the LWPF in the 200 East Area of the Hanford
Site for treatment and disposal. Wastewaters are coUected in basins at the LERP prior to treatment
in the ETF to eliminate hazardous and radioactive constituents. Treated wastewaters from the ETF
are disposed to the ground. Effluent from the ETF has been the subject of a previous delistine
petition approved by the EPA in 1995 (60 FR 6054).
Under 40 CFR §§ 260.20 and 260.22, facilities may petition the EPA to remove their wastes from
hazardous waste control by excluding them from the.lists of hazardous wastes contained in §§
261.31 and 261.32. Petitioners must provide sufficient information to EPA to allow the Agency to
determine that the waste to be excluded does not meet any of the criteria under which the waste was
listed as a hazardous waste. In addition, EPA must determine, where there is a reasonable basis to
beheve that factors (including additional constituents) other than those for which the waste was listed
could cause the waste to be a hazardous waste, that such factors do not warrant retaining the waste
as a hazardous waste.
In October 1998, the DOE submitted the Environmental Restoration Disposal Facility Leachate
Delisting Petition (the Petition). The Petition describes the history of leachate management at
ERDF, rational for selection of contaminants of concern, and a proposed sampling and analysis plan
for the delisting. The Petition also includes an analysis of current and potential contaminants of
concern anticipated for waste disposal at the facility. Previous leachate characterization data
indicated that^constituent concentrations were below delisting levels (See Table 1), which account
for some minimal dilution and attenuation, although a few were above actual docket values (See
Docket Report on Health-Based Levels and Solubilities Used in the Evaluation of Delisting
Petitions, Submitted under 40 CFR 260.20 and 260.22, May 1996), which do not account for any
dilution or attenuation. These data were not subject to full validation and did not evaluate all of the
constituents of concern, and therefore serve only as a preliminary indication of the concentrations
of hazardous constituents in the leachate. The first round of sampling, consistent with the delisting
sampling and analysis plan attached to this Amendment, was completed in January of 1999 and the
validated data package was submitted to EPA. The EPA evaluated the information and the analytical
data provided by DOE and determined that the levels of the constituents were well below the
delisting levels in Table 1 and that management of the leachate as a non hazardous waste would not
adversely affect human health or the environment. The data package may be found hi the
Administrative Record for ERDF.
The delisting is an up-front and conditional delisting for leachate, including leachate that will be
generated in the future operations of the facility. The delisting is conditional because contaminant
concentration requirements specified in this amendment and in the sampling and analysis plan
attached to this amendment must continue to be satisfied and management of the leachate must
comply with the sampling and analysis plan and the leachate management plan, as approved by the
EPA. Ongoing exclusion from management as a hazardous waste is conditioned on compliance with
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specified management requirements and on the leachate meeting the limits established in this
Amendment, as demonstrated through a verification sampling program.
In order to delist the leachate, it must be demonstrated that the concentrations of hazardous
contaminants found m the leachate satisfy the requirement for an exclusion under 40 CFR § 260 22
r sn?fZXCeSd the Criteria f°r characteristic wast«s as defined under 40 CFR Part 261 Subpart
U and WAC 173-303-090. In order to confirm that the concentration of hazardous constituents in
toe leachate continue to be below delisting levels, a sampling and analysis plan supporting the
delisting is attached to this ROD Amendment. The plan provides detail regarding sampling
frequency and methodology and specified analytical methods. The sampling and analyses shall
include comparison of leachate sample results with delisting levels. Delisting levels, in general are
based on the original docket values and health-based limits presented in Table 1. The table lists all
of the identified constituents of concern (COCs) for the leachate. The initial list of COCs included
the Toxicity Characteristic Analytes from 40 CFR § 261.24, the Appendix VTf list of chemicals and
compounds from 40 CFRPart261. These lists of constituents provide the basis for which F001 and
F0.?9 are listed. Also included in the initial list were additional analytes from the EPA document
enttledPetitions to Delist Hazardous Wastes, A Guidance Manual, and the list of analytes presented
in the EPA docket list The list was then compared in a thorough evaluation to regulated compounds
that have been previously used and disposed of at Hanford, and revised to include only those
potential contaminants. The complete evaluation is included within the Petition Under the
sampling and analysis plan, at a minimum, the leachate shall be sampled for all COCs, quarterly for
the first year. The results of subsequent analyses will be compared to the delisting levels provided
in Table 1. If the leachate continues to achieve compliance with delisting levels, it will be managed
as nonhazardous. Those COCs whose analytical results from baseline sampling indicate that their
concentrations are less than 10% of the delisting level will be moved into a confirmatory samplin*
regimen. COCs detected at concentrations greater than 10% of the delisting level willbe'monitored
on a routine basis. DOE shall include additional constituents in the routine samplin* list after an
evaluation of the data, as required by the EPA. Additionally, an evaluation of the waste streams
going to the ERDF shall be done biannually, in accordance with the sampling and analysis plan to
assure that the h'st of COCs adequately addresses contaminants being disposed Confirmatory
sampling for all COCs will take place every two years. Routine sampling will take place every six
months. J
Over time, it is anticipated that waste compounds will be placed in ERDF that have not been
evaluated through previous analysis of leachate. Waste profiles will be evaluated for the presence
of compounds that are not on record as contained in ERDF waste biannually, in accordance with the
sampling and analysis plan. These compounds will be evaluated against the initial list of COCs to
determine if they should be included in future sampling and if they are identified on existing EPA
docket lists.
Prior to January 1999, leachate analysis had been conducted primarily to characterize water quality
for shipment to ETF. Not all COCs were sampled for this effort. Table 1 lists the maximum
detected results for those COCs that were analyzed for in the leachate; if more than one sample
showed the presence of a constituent, the highest value is reported.
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Table 2 list constituents that are considered COCs in that they were retained through the evaluation
of compounds used and disposed of at Hanford. These constituents, however, are not listed in the
EPA docket nor are there established ground water quality criteria. The constituents will be
sampled quarterly, for the first year, and then will be moved to the confirmatory sampling regimen.
At such time that EPA waste docket values are established for these constituents, they will include
these in the delisting criteria for this delisting and will be subject to the confirmatory sampling
requirements.
Table 1. Environmental Restoration Disposal Facility
CAS#
100-41-4
100-42-5
100-51-6
1024-57-3
105-67-9
106-46-7
106-50-3
106-93-4
107-02-8
107-05-1
107-06-2
107-13-1
108-05-4
108-10-1
108-60-1
108-88-3
108-90-7
108-95-2
110-86-1
111-44-4
117-81-7
117-84-0
120-12-7
120-82-1
120-83-2
122-39-4
122-66-7
123-91-1
124-48-1
—————— —^———— —^_ B _
Constituent
Ethyl benzene
Styrene
Benzyl alcohol
Heptachlor epoxide
2,4-DimcthyIphenol
1 ,4-Dichlorobenzene
3-PhenyIenediaming
Ethylene dibromide
Acrolein
3-Chloropropene
1 ,2-Dichloroethane
Acrylonitrile
Acetic acid vinyl ester
4-Methyl-2-pentanone
Bis(2-Chloroisopropyl) ether
Toluene
Chlorobenzene
Phenol
Pyridine
Bis(2-chloroethyl) ether
Bis(2-ethylhexyl) phthalate
Di-n-octylphthalate
Anthracene
,2,4-TrichIorobenzene
,4-Dichlorophenol
N',N-Diphenylamine
,2-Diphenylhydrazine
,4-Dtoxane
Dibromochloromethane
Docket
Value *
70000
100
10000
0.2
700
4
7000
0.05
700
4
D
0.2
40000
2000
1
1000
[00
20000
40
0.08
6
700
10000
70
00
900
0.1
Delisting
Level '
1680000
2400
240000
4.8
16800
96
168000
1.2
16800
96
120
4.8
960000
48000
24
24000
2400
480000
960
1.92
144
16800
240000
1680
2400
21600
2.4
192
24
Maximum
Concentration
Detected in
Leachate *
NT)
ND
NA
NA
ND
ND
NA
NA
NA
NA
ND
NA
NA
, ND
ND
2J
ND
ND
NA
ND
14
ND
ND
ND
ND
NA
NA
NA
ND
8
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CAS#
126-98-7
127-18-4
129-00-0
131-11-3
1319-77-3
1330-20-7
1336-36-3
141-78-6
14797-55-8
156-59-2
156-60-5
16984-48-8
193-39-5
205-99-2
206-44-0
207-08-9
218-01-9
309-00-2
319-84-6
319-85-7
50-00-0
50-29-3
50-32-8
51-28-5
53-70-3
541-73-1
542-75-6
56-23-5
56-55-3
57-12-5
58-89-9
59-50-7
60-29-7 ]
60-57-1 ]
62-50-0 ]
62-53-3 t
62-75-9 I
621-64-7 I
67-56-1 }
67-64-1 2
67-66-3 C
Constituent
2-Methyl-2-propenenitrile
1 , 1 ,2,2-Tetrachloroethene
Pyrene
Dimethyl phthalate
Cresols, total "
Xylene
Polychlorinated biphenyk (PCBs)
Acetic acid ethyl ester
Nitrate
1 ,2-cis-Dichloroethene
1 ,2-trans-Dichloroethene
Fluoride
Indeno( l,2,3-cd)pyrene
Benzo(b)fluoranthene
Fluoranthene
Benzo(k)fluoranthene
Chrysene
Aldrin
alpha-BHC
beta-BHC
Formaldehyde
4,4-DDT
Benzo(a)pyrene
2,4-Dinirrophenol
Dibenz[a,h]anthracene
1 ,3-Dichlorobenzene
1 ,3-Dichloropropene
Carbon tetrachloride
Benzo(a)anthracene
Cyanide
jamma-BHC (lindane)
4-Chloro-3-methylphenol
Bthyl ether • . •
Dieldrin (
:thyl methanesulfonate i
Vmline
^-Nitroso-N,N-dimethylamine i
^-Nitroso-di-n-propylamine (
Methyl alcohol ^
-Propanone (acetone) t
-.hloroibrm i
I
Docket
Value*
4
5
1000
400000
2000
10000
0.5
30000
10000
400
700
4000
0.21
D.071
1000
25.2
2.7
0.005
0.01
0.05
7000
0.3
0.2
70
3.011
:,890
3.5
5
).077
200
3.2
[260
7000
3.005
).0003
0
).002
1.01
10000
Delisting
Level '
96
120
24000
9600000
48000
240000
12
720000
240000
)600
:6800
>6000
5.04
.704
:4000
604.8
64.8
.12
.24
2
68000
t
4.8
1680
D.264
45360
12
120
1.848
*800
t.8
J0240
168000
3.12
X0072
>40
).04S
).24
•80000
000 (96000
00 2400
Maximum
Concentration
Detected in
Leachate *
NA
ND
TIC
ND
ND
ND
NA
NA
19300
NA
NA
1180
ND
ND
TIC
ND
ND
ND
NA
NA
NA
ND
ND
ND
ND
ND
NA
ND
ND
NA
ND
ND
NA
ND
NA
NA
NA
ND
NA
17 J
ND
-------
CAS#
67-72-1
70-30-4
71-36-3
71-43-2
71-55-6
72-20-8
72-54-8
72-55-9
74-83-9
74-87-3
7439-92-1
7439-96-5
7439-97-6
7440-02-0
7440-22-4
7440-28-0
7440-31-5
7440-36-0
7440-38-2
7440-39-3
7440-41-7
7440-43-9
7440-47-3
7440-18-4
7440-50-8
7440-62-2
7440-66-6
75-01-4
75-05-8
75-09-2
75-15-0
75-25-2
75-27-4
75-34-3
75-35-4
75-69-4
75-71-8 I
76-13-1 ]
76-44-8 I
7782-49-2 S
78-59-1 I
Constituent
Hexachloroethane
Hexachlorophene
n-Butyl alcohol
Benzene
1,1, 1-Trichloroethane
Endrin
4,4-DDD
4,4-DDE
Bromomethane
Chloromethane
Lead
Manganese
Mercury
Nickel
Silver
Thallium
Tin, metal
Antimony
Arsenic
Barium
Beryllium
radnuum
Chromium
Cobalt
Copper
Vanadium
Zinc
1-Chloroethcne (vinyl chloride)
Acetonitrile
Dichloromethane (methylene chloride)
Carbon disulfide
rribromomethane
Bromodichloromethane
I , 1-Dichloroethane
1 , 1 -Dichloroethene
rrichlorofluoromethane
Dichlorodifluoromethane
,2,2-Trichlorotrifluoroethane (Freon 1 13)
leptachlor
selenium
sophorone
Docket
Value"
6
10
4000
5
200
2
).4
).3
50
33.7
5
00
2
100
200
2
21000
6
50
2000
4
5
100
2100
300
300
10000
2
200
5
tooo
00
.4
L9
7
oooo :
wo
oooooo :
.1 :
0 ]
Delisting
Level '
144
240
96000
120
4800
48
9.6
7.2
1200
808.3
360
2400
48
2400
4800
48
504000
144
1200
48000
96
120
2400
50400
31200
7200
240000
48
4800
120
?6000
2400
33.6
21.6
:68
>40000
68000
'4000000
>.4
200
0 (2160
Maximum
Concentration
Detected in
Leachate *
ND
NA
NA
ND
ND
ND
ND
ND
ND
ND
ND
17.7
0.16J
10.2 J
ND
ND
NA
ND
32.6
63.3 J
0.77 J
ND
13.9
ND
6.4 J
52 9
49 7
ND
NA
ND
ND
ND
ND
ND
ND
NA .
NA
NA
ND
3.1 J
ND
12
-------
CAS#
78-83-1
78-87-5
78-93-3
79-00-5
79-01-6
79-34-5
8001-35-2
83-32-9
84-66-2
84-74-2
85-68-7
86-30-6
86-73-7
87-68-3
87-86-5
88-06-2
91-20-3
91-58-7
91-59-8
94-75-7
95-50-1
95-57-8
95-70-5
95-95-4
98-82-8
98-86-2
98-95-3
99-65-0
Constituent
2-Methylpropyl alcohol
1 ,2-Dichloropropane
2-Butanone (MEK)
1 , 1 ,2-Trichloroethane
1 , 1 ,2-Trichloroethylene
1 , 1 ,2,2-Tetrachloroethane
Toxaphene
Acenaphthene
Diethyl phthalate
Di-n-butylphthalate
Butylbenzylphthalate
N-Nitrosodiphenylamine
Fluorene
Hexachlorobutadiene
Pentachlorophenol
2,4,6-Trichlorophenol
Naphthalene
2-Chloronaphthalene
2-Naphthylamine
2,4-D
,2-Dichlorobenzene
-Chlorophenol
, 5-Diaminoto luene
,4,5-Trichlorophenol
1 -Methylethyl)benzene
A.cetophenone
Nitrobenzene
, j -Dinitrobenzene
Docket
Value *
10000
5
20000
5
8
14
3
2000
30000
4000
7000
20
LOGO
I
).7
5
.000
3000
).l
70
600
200
96000
4000
1000
4000
20
4
Detisting
Level *
240000
120
480000
120
192
9.6
72
48000
720000
96000
168000
480
24000
24
[6.8
:92
24000
72000
2.4
680
4400
•800
2304000
96000
24000
6000
80
6
Maximum :
Concentration
Detected in
Leachate'
NA •
ND
ND
ND
ND
ND
ND
ND
ND
TIC
9J
ND
ND
ND
ND
ND
TIC
ND
NA
ND
ND
ND
NA
ND
NA
NA
ND
NA
*ALL RESULTS cv p.cfL EXCEPT WHERE NOTED
CAS# = chemical abstract services number
J = estimated value
NA = not analyzed
ND = not detected
TIC = tentatively identified compound
11
-------
Table 2. Environmental Restoration Disposal Facility
Other Constituents of Concern.
CAS#
100-02-7
101-55-3
106-99-0
109-99-9
110-75-8
111-91-1
126-58-1
131-89-5
134-32-7
14265-44-2
14797-65-0
14808-79-8
1634-02-2
16887-00-6
22781-23-3
24959-67-9
26545-73-3
57-97-6
59-89-2
591-08-2
7429-90-5
7439-95-4
7440-21-3
75-00-3
75-70-7
7664-41-7
Constituent
4-Nitrophenol
4-BromophenylphenyI ether
1,3-Butadiene
Tetrahydrofuran (THF - furan indicator)
2-Chloroethyl vinyl ether
Bis(2-Chloroethoxy)methane
O,O,O-Triethyl phosphorothioate
2-Cyclohexyl-4,6-dimtrophenol
alpha-Naphthylamine
Phosphate
Nitrite
Sulfate
Tetrabutylthiuram disulfide
Chloride
Bendiocarb
Bromide
Dichloropropanol
7, 12-Dimethylbenz[a]anthracene
N-NitrosomorphoIine
1 -Acety 1-2-thiourea
Aluminum
Maenesium
Silicon
Chloroethane
Trichloromethancthiol
Ammonia
Maximum Concentration
Detected in Leachate A
ND
ND
NA
NA
NA
ND
NA
NA
NA
840
ND
534000
NA
443000
ND
NA
NA
NA
NA
NA
213
65300
NA
ND
NA
285
AALL RESULTS IN JIG/L EXCEPT WHERE NOTED.
CAS# = chemical abstract services number
NA » not analyzed
ND = not detected
In general, the delisting level for a particular constituent contained in the ERDF leachate is set at
the lower of (1) the characteristic dangerous waste levels found in the Washington Administrative
Code (WAG) Section 173-303, for determining the characteristic aspects of the waste or (?)
constituent concentrations provided in the EPA docket multipKed by 24. The docket value's were
provided to DOE by EPA Region 10 staff and represent health-based values for these specific
constituents. The "24 tunes" factor represents a dilution/attenuation factor (DAF) developed
according to the procedures set forth in the Composite Model for Landfills (EPACML), found in
12
-------
56 FR 33000, July 18, 1991. This DAF is based on waste volume of 3,500,000 gallons per year
managed in an unlined surface impoundment, the worst-case management scenario for the
leachate. The delisting levels establish values for constituents below which the leachate would
satisfy the requirement for an exclusion under 40 CFR § 260.22 and do not exceed the criteria for
characteristic wastes as defined under 40 CFR Part 261 Subpart C and WAC 173-303-090 All
leachate from the ERDF will continue to be sent to the ETF for treatment.
To date, ERDF has collected approximately 7,571,000 L (2 million gal) of leachate from two
disposal cells. Approximately 6,814,000 L (1.8 million gal) of this water has been trucked to the
200 Area LWPF for processing, and 757,100 L (0.2 million gal) were retained in the leachate and
washwater storage units, used for dust suppression or waste compaction, or lost to evaporation.
After delisting, the DOE intends to utilize a single-walled pipeline for transport of the leachate
from ERDF to the LWPF. A flowmeter has been installed at the beginning of the pipeline to
measure the volumes of leachate pumped from the ERDF modu-tanks to the LWPF. Another
flowmeter has been installed at the LERF end of the pipeline. If DOE chooses to use the single-
walled pipeline, then the two meters shall be monitored, in accordance with the leachate
management plan, to ensure that a mass balance is maintained, thereby assuring that the potential
for major leaks along the pipeline are minimized.
A limited volume of the leachate may be recycled, as appropriate, in the disposal cells.
Appropriate uses are limited to dust suppression and waste compaction. The approved
operations plan for the ERDF specifies that compaction of the waste must achieve 90% of
optimum density. Compaction of the waste is necessary to minimize the potential for subsidence
and to support a final surface cover. It may be necessary to add nonhazardous liquid to the waste
m order to achieve the required compaction. Use of a nonhazardous liquid for dust suppression
is necessary for compliance with the Washington Administrative Code, WAC 246-247, Air
Emission standards. The use of delisted leachate solely for dust suppression and waste *
compaction is not subject to the prohibition on the placement of non hazardous liquids in
landfills found at Section 3004(c)(3) of RCRA (See the April 1986 OSWER Directive £9487.01-
1 A(85) Restriction on the Placement of Nonhazardous Liquids in Hazardous Waste Landfills)
The ARAR waiver of RCRA 3004(c)(l) regarding use of hazardous waste liquids in a landfill,
which was established in the ERDF ESD, is no longer necessary and is revoked. The selected
ERDF remedy must comply with the ARAR. The volume of leachate used to suppress dust and
compact waste within the landfill must be equal to or less than the minimum volume of water
that otherwise would be necessary for these purposes. The ERDF will utilize ETF or some other
authorized treatment facility for wastewater exceeding annual operation needs.
If detected concentrations exceed the delisting value for a particular constituent, the results shall
be immediately reported to the EPA for a determination concerning the appropriate response
action. If a constituent in the leachate exceeds the delisting levels established in this amendment,
and the EPA has not adjusted the limit for that constituent, use of the single-walled pipeline shall'
cease immediately and the DOE/Environmental Restoration Contractor (ERC) will handle the
leachate under established, RCRA compliant, management procedures for the leachate, after
consultation with the EPA.
13
-------
A leachate management plan has been submitted to and approved by the EPA as part of the
indicate that dehstmg levels have been exceeded and submitted to the EPA for approval
V- EVALUATION OF AT.TERNATTVF.S
e Criteria f°r evaluatillg ^edial action alternatives. These criteria are
Cf°neS o*™®** importance which include: threshold, balancing
modifying catena. All remedies must meet the threshold criteria to be considered The s
rered by CERCl t0 ^ ^ criteria
Summary of Alternatives
The key elements of each alternative are described and briefly discussed below.
Alternative 1 - No Action. The no action alternative consists of not delisting the ERDF
leachate. Leachate would continue to be managed as a hazardous waste. The waiver which
allows use of leachate in the trench for dust suppression would continue.
2n CERCtA DeUsting of ERDF Leachate. Delist ERDF leachate under
m°re COSt"effeCtiVe *"* aPPr°Priate leachate handling techniques to be
Evaluation of Alternatives
L °^all protection of human health and the environment: Both alternatives would
satisfy the overall protection of human health and the environment criterion.
2. Compliance with ARARs: The key ARAR for the facility is the Resource Conservation
^Vn?^ ySC,6901 Ct Seq" Subdtle C ^ Wa^gton Administrative
, * JL > s 5 ^ ^™AC 1?3-303 regUlate ±e Station, transportation,
A « f ' to!atment' md disposal of hazardous waste. Alternative 1 would require an
ARAR waiver. Alternative 2 would comply with ARARs.
3. Long-term effectiveness and permanence: Both alternatives would satisfy this
criterion However, delisting would enable long-term, effective handling of the leachate
as a nonhazardous waste stream.
°f toxicitv» mobility, or volume through treatment: For both alternatives
ERDF leachate would continue to be treated at the ETF to reduce toxicity mobility or
volume as necessary.
H
-------
5. Short-term effectiveness: Delisting would enable more effective handlin- of ERDF
leachate m the short term. Transportation of leachate to ETF by pipeline is more
effective than transport by individual truck.
6. Implementability: Management of the leachate as a delisted waste is readily
implementable.
7. Cost: An overall cost savings is likely to be recognized by delisting the leachate waste
stream because it is anticipated that it would not have to be handled '
hazardous waste.
8. State acceptance: The State
9.
as
, , * OJ concurs with the"
leachate.
Community acceptance: Newspaper notices, a fact sheet, and a proposed plan were
issued^ support starting public comment on November 2, 1998. Several comments were
received during the 30-day public comment period. The comments supported the
delisting and are included in the Responsiveness Summary attached to this Amendment.
V*' SELECTEn AMENDED REMEDY FOR THE ERDF
The selected remedy modification for the.ERDF is to delist the leachate. Delistina the ERDF
leachate under CERCLA to allow more cost-effective and appropriate leachate haSdimg
techniques to be implemented is considered the best option. A detailed description of the
AmenH^611^ ^^ •* ^ * Secti°n ™ V^P*™ of the Modified Remedy) of this
Amended Record of Decision for the ERDF. The ARARs for this amended remedy are
unchanged from those specified in the 1995 ERDF ROD except that ERDF leachate that is
otherwise identified as a hazardous or dangerous waste is delisted for purposes of the ROD
pursuant to RCRA and WAC 173-303-910. p«P°ses °i me KULJ
STATUTORY DETTTK\rTNATIONS
The delisting process is based on the regulations established by the EPA as set out in Title 40
Code of Federal Regulations (CFR), Section 260.22 and at WAC 173-303-910.
The EPA and Ecology believe that the amended ROD remains protective of human health and
the environment, complies with Federal and State requirements that are applicable or re evant
and appropriate to this remedial action, and is cost-effective. This remedy utilizes permLm
solutions to the maximum extent practicable for this site. Treatment of ERDF leachate at the
017 PreferenCe f°r remedies ** emPIoy treatment as a principal element
Treatment of remediation wastes will continue to be addressed as part of the operable unit
decisions. As a consequence, the statutory preference for treatment as a principal element will be
addressed m those current and future documents rather than in this ROD
15
-------
Vm- DOCUMENTATION OF SIGNIFICANT CHANOFS
DOE and EPA reviewed all written and verbal comments submitted during the public comment
period. Upon review of these comments, it was determined that no significant changes to the
amended remedy, as originally identified in the Proposed Plan, were necessary.
E*. RESPONSIVENESS STJMiVTAttV
U.S. Department of Energy
Environmental Restoration Disposal Facility
Hanford Site
Benton County, Washington
Amended Record of Decision
Introduction
This responsiveness summary meets the requirements of Section 117 of the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) as amended The
purpose of this responsiveness summary is to summarize and respond to public comments on the
proposed amendment for the January 1995 Record of Decision (ROD) for the Hanford
Environmental Restoration Disposal Facility. The proposed plan for the Amendment issued on
November 2, 1998, was presented for public comment (on the proposed changes to components
of the remedy set forth in the January 1995 ROD).
The Tri-Parties announced the issuance of the proposed plan in the community newspaper A
thirty-day comment period was provided for the public to read the proposed plan, review
documents in the administrative record, and submit written comments. No request was made for
a public meeting, therefore, no meeting was held. The proposed plan discusses the delisting of
the ERDF leachate.
Community Involvement
A newspaper notice was placed in the Tri-City Herald on November 1, 1998 announcing the
availability of the proposed amendment and the start of the public comment period
Approximately fourteen hundred copies of a fact sheet describing the amendment proposal were
mailed out. A public comment period was held from November 2 through December 1 1998
No requests were received for a public meeting, therefore, no public meeting was held '"The
proposed amendment was presented to the Hanford Advisory Board (HAS) and the HAS
Environmental Restoration Committee in October 1998.
Comments and Responses
The EPA received two written comments and one verbal comment during the public comment
period. All comments received supported the delisting of the ERDF leachate as proposed. No
specific comments, requiring a detailed response, were submitted.
16
-------
JUN 07 1939
Environmental
Restoration Disposal
Facility Leachate
Sampling and Analysis
Plan
-------
-------
CONTENTS
! .0 SAMPLING AND ANALYSIS PLAN ..„ 1
1.1 SAMPLING OBJECTIVES 1
1.2 ANALYTICAL DESIGN 1
1.2.1 Non-Delisting-Related Test Parameters 14
1.2.2 Rationale 14
1.2.3 Sampling Strategy 16
1.3 PROJECT ORGANIZATION AND RESPONSIBILITY 17
1.3.1 Project Responsibility 17
1.3.2 Support Responsibilities 17
1.4 SAMPLE COLLECTION "..'l8
1.4.1 Sample Collection Techniques 18
1.4.2 Sample Volume. Preservation, and Holding Times 18
1.4.3 Sample Documentation.. 21
1.4.4 Sample Identification and Labeling 21
1.4.5 Chain-of-Custody Procedures ....21
1.4.6 Sample Packaging and Shipping 22
1.5 SAMPLING QUALITY ASSURANCE AND QUALITY CONTROL 22
1.5.1 Equipment Operation and Calibration 22
1.5.2 Preventive Maintenance 22
1.5.3 Field Quality Control Requirements 23
1.6 LABORATORY ANALYSIS 24
1.6.1 Analytical Methods 24
1.6.2 Detection Limits 24
1.6.3 Volatile Organic Analysis 30
1.6.4 Semi-Volatile Organic Analysis 31
1.6.5 Polynuclear Aromatic Organic Analysis by Method 8310 32
1.6.6 Pesticide Analysis by Method 8081A 32
1.6.7 Bendiocarb Analysis 32
1.6.8 Laboratory Quality Assurance and Control 33
1.6.9 Laboratory Quality Control Acceptance Criteria 33
1.7 DATA MANAGEMENT 33
1.7.1 Data Reporting 33
1.7.2 Data Validation .*.... 34
1.7.3 Data Management 34
1.8 AUDITING AND ASSESSMENT 34
1.9 DATA QUALITY ASSESSMENT 35
2.0 REFERENCES ; ; 36
111
-------
FIGURE
1. Hanford Site Annual Precipitation Values. 1946-1997 15
TABLES
1. Initial Baseline Organic and Inorganic Contaminants of Concern 2
2. ERDF Delisting Levels and Comparison to Baseline Analytical Results. 8
3. Potential Contaminants with No Delisting Levels 13
4. Sampling and Holding Time Requirements for the Contaminants of Concern
Analytical Methods 19
;
5. Comparison of Delisting Levels and Method Detection Limits for the
Contaminants of Concern 25
IV
-------
1.0 SAMPLING AND ANALYSIS PLAN
This document provides the sampling and analysis plan (SAP) and sampling objectives for the
Environmental Restoration Disposal Facility (ERDF) leachate. Approved handling methods and
conditional delisting of the leachate will be based on the requirements of this SAP?
1.1 SAMPLING OBJECTIVES
There are two alternatives for handling the ERDF leachate: store the leachate and reuse it at the
ERDF. or convey the leachate to the Liquid Waste Processing Facility (LWPF) for treatment.
Authorized alternatives for reuse of the leachate include dust suppression and waste compaction
within the trench. These two alternatives will continue as methods to manage the leachate.
Whether the leachate is reused or conveyed to the LWPF. sampling is required to determine
initial and ongoing compliance with the delisting criteria. Characterization data also will be
required for treatment at the Effluent Treatment Facility (ETF). Therefore, the objectives of
leachate sampling are as follows:
1. Collect baseline information to determine whether the leachate can be delisted on a
compound-by-compound basis.
2. Evaluate the ongoing compliance of the leachate with delisting criteria.
3. Determine the profile for liquid that will be transferred to the LWPF.
The sampling logic for completing these objectives is provided in the Environmental Restoration
Disposal Facility Leachate Delisting Petition (DOE-RL 1998). The eligibility of the leachate for
delisting will be determined through analysis of characterization samples. Routine sampling will
provide data to support objectives 2 and 3. The basic premise of the sampling logic is that all
contaminants of concern (COC) are placed into one of two groups: those that will be monitored
on a confirmatory basis, and those that will be monitored on a routine basis.
1.2 ANALYTICAL DESIGN
The organic and inorganic COC list for characterization includes the following:
• Regulated compounds previously detected in the leachate
• Compounds not found in the leachate but determined to require additional monitoring
• The list of compounds and test parameters derived in the delisting petition
(DOE-RL 1998).
Characterization sampling has taken place to establish the baseline constituent values for the
leachate. The list of initial COCs that will be evaluated for delisting and the analytical results are
presented in Table 1.
-------
Table 1. Initial Baseline Organic and Inorganic Contaminants of Concern.
(6 sheets)
CAS#
100-02-7
1 00-4 1-4
100-42-5
100-51-6
101-55-3
1024-57-3
105-67-9
• 106-46-7
i 106-50-3
106-93-4
106-99-0
107-02-8
107-05-1
107-06-2
107-13-1
108-05-4
108-10-1
108-60-1
108-88-3
108-90-7
108-95-2
109-99-9
1 10-75-8
III 0-86- 1
111-44-4
111-91-1
117-81-7
117-84-0
120-12-7
120-82-1
120-83-2
122-39-4
Constituent
4-NitrophenoI
Ethyl benzene
Styrene
Benzyl alcohol
4-Bromophenylphenyl ether
Heptachlor epoxide
2.4-DimethylphenoI
1 ,4-Dichlorobenzene
p-Phenylenediamine
Ethylene dibromide
1.3-Butadiene
Acrolein
3-Chloropropene (allyl chloride)
1 ,2-Dichloroethane
Acrylonitrile
Acetic acid vinyl ester (vinyl acetate)
4-Methyl-2-pentanone (MIBK.)
Bis(2-Chloroisopropyl) ether
Toluene
Chlorobenzene
Phenol
Tetrahydrofuran (THF - furan indicator)
2-Chloroethyl vinyl ether
Pyridine
Bis(2-chloroethyl) ether
Bis(2-Chloroethoxy)methane
Bis(2-ethylhexyl) phthalate
Di-n-octylphthalate
Anthracene
1 .2.4-Trichlorobenzene
2,4-Dichlorophenol
N,N-Diphenylamine
SW-846
Method
8270C
8260B
8260B
8270C
8270C .
8081 A
8270C
8270C
8270C
8260B
8260B
8260B
8260B
8260B
8260B
8260B
8270C
8260B
8260B
8270C
8260B
8270C
8270C
8270C
8270C
8270C
8270Cor8310
8270C
8270C
8270C
Alternate Analytical
Method
i
i
8260B
i
8270C
1
-------
Table 1. Initial Baseline Organic and Inorganic Contaminants of Concern.
(6 sheets)
CAS#
: 122-66-7
i 123-91-1
i 124-48-1
126-68-1
126-98-7
i 127-18-4
129-00-0
; 131-11-3
131-89-5
1319-77-3
• 1330-20-7 '
1336-36-3
134-32-7
. 141-78-6
14265-44-2
j
14797-55-8
14797-65-0
14808-79-8
I 156-59-2
. 1 56-60-5
1634-02-2
16887-00-6
16984-48-8
193-39-5
205-99-2
206-44-0
Constituent ; JW-846
| Method
i 1.2-Diphenylhydrazine 8270C
! 1.4-Dioxane 8270C
Dibromochloromethane 8260B
O.O.O-Triethyl phosphorothioate 8270C
i 2-Methyl-2-propenenitrile ' 8260 B or 83 10
!(methacrylonitrile)
1.1.2.2-Tetrachloroethene : 8260B
Pyrene |8270Cor8310
Dimethyl phthalate 8270C
2-Cyclohexyl-4.6-dinitrophenol 8270C
Cresols. total 8270C
Xylene i 8260B
Polychlorinated biphenyls (PCBs) I 8082
alpha-Naphthylamine • 8270C
Acetic acid ethyl ester (ethyl acetate) 8260B
Phosphate 9056 or 300.0
or 365.2
Nitrate 9056 or 300.0
Nitrite 9056 or 300.0
Sulfate i 9056 or 300.0
1 .2-cis-Dichloroethene
1.2-trans-Dichloroethene 8260B
Tetrabutylthiuram disulfide ;
Chloride 9056
Fluoride j 9056 or 300.0
Indeno( 1 .2.3-cd)pyrene 8270Cor 83 1 0
Benzo(b)fluoranthene | 8270C
Fluoranthene |8270Cor8310
. Alternate Analytical
i Method
i
!
1
8260B
9030B or 376.1
8310
| Benzo(k)fluoranthene
8270Cor8310
L~
218-01-9
22781-23-3
24959-67-9
Chrysene
Bendiocarb
Bromide"
8270Cor8310
8318
9056 or 300.0
-------
Table 1. Initial Baseline Organic and Inorganic Contaminants of Concern.
(6 sheets)
[
j CAS#
i
126545-73-3
Constituent
SW-846
i Method
Alternate Analytical
Method
Dichloropropanol . 8260B
309-00-2 .Aldrin 8081 A :
• 3 19-84-6 Alpha-BHC 8081 A
•319-85-7
50-00-0
Beta-BHC j 8081A
Formaldehyde
8315A
50-29-3 ;4,4-DDT j 808IA
50-j2-8 | Benzo(a)pyrene
— 1 -.
:• 1 -28-5 2.4-DinitrophenoI
1 53-70-3 ! Dibenz[a.h]anthracene
: 54 1-73-1 | 1.3-Dichlorobenzene
8270Cor8310
1 6252B
8310
8270C ;
8270C .-. 8310
8270C
,542-7^-6 l.j-Dichloropropene ; 8260B
! 56-23-5
J56-55-3
'57-12-5
57-97-6
j Carbon tetrachloride
Benzo{a)anthracene
Cyanide
7, 12-Dimethylbenz[a]anthracene
58-89-9 Gamma-BHC (lindane)
59-50-7
! 59-89-2
4-Chloro-3-methylphenol
. 8260B
8270C
901 OB
8270C
8310
8081A ;
8270C
N-Nitrosomorpholine ' 8270C !
591-08-2 I-Acetyl-2-thiourea
60-29-7 Ethyl ether
60-57-1
1 62-50-0
62-53-3
62-75-9
621-64-7
67-56-1
'67-64-1
67-66-3
67-72-1
70-30-4
71-36-3
i
71-43-2
i_
Dieldrin
Ethyl methanesulfonate
Aniline
N-Nitroso-N.N-dimethylamine
N-Nitroso-di-n-propylamine
8270C
8260B
8081 A
8270C
8270C
8270C !
8270C
Methyl alcohol go 15
2-Propanone (acetone)
Chloroform
Hexachloroethane
Hexachlorophene
8260B
8260B
8270C
8270C
n-Butyl alcohol | 8260B
Benzene 8260B
8070A
8070A
i
— ,
i
-------
Table 1. Initial Baseline Organic and Inorganic Contaminants of Concern.
(6 sheets)
1
CAS#
Constituent . JJ^
Method
Alternate Analytical
Method
71-55-6 : I.I.I -Trichioroethane 8260B :
72-20-8 Endrin 8081 A ;
72-54-8
4,4-DDD 8081 A
72-55-9 4,4-DDE 8081 A
: 74-83-9 Bromomethane = 8260B
j 74-87-3 Chloromethane ; 8260B
' 7429-90-5
'7439-92-1
7439-95-4
Aluminum 60|OB '
Lead 601 OB :
{
Magnesium" 601 OB j
7439-96-5 Manganese ; 60 1 OB ;
7439-97-6
7440-02-0
7440-21-3
7440-22-4
7440-28-0
7440-31-5
7440-36-0
Mercury . 7470A
Nickel : 60 1 OB
Silicon" .: 60IOB
Silver 6010B '
Thallium 601 OB
Tin 60 1 OB
Antimony 601 OB
7440-38-2 i Arsenic 6010B
7440-39-3
7440-41-7
7440-43-9
7440-47-3
7440-48-4
7440-50-8
7440-62-2
7440-66-6
Barium 601 OB
Beryllium : 601 OB
Cadmium i 60 1 OB
Chromium ; 601 OB
Cobalt j 601 OB
Copper 601 OB i
Vanadium 601 OB
Zinc 601 OB
75-00-3 Chloroethane i 8260B
75-01-4 1-Chloroethene (vinyl chloride) ! 8260B
75-05-8
Acetonitrile : 8260B
75-09-2 Dichloromethane (methylene chloride) . 8260B
i
75-15-0 Carbon disulfide ' • 8260B j
75-25-2 iTribromomethane(bromoform) 8260B
-------
Tab,e I. InWal BaseUne Organic and ,norganic Contanlinailts of Concern
(6 sheets)
CAS#
Constituent
; Bromodichloromethane
_
I.l-Dichloroethane
.1-Dichloroethene
i Trichlorofluoromethane
j Trichloromethanethiol
"
j Dichlorodifluoromethane
.
2.2-Trichlorotrifluoroethane(Freon
Heprachlor
Ammonia
I Selenium
•• —
I Isophorone
Methvlpropyl alcohol (isobutyl alcohol)
1.2-Dichloropropane
— —
2-Butanone (MEK)
' :
l.I.2-Trichloroethane
—• •—•
1,1.2-Trichloroethylene
i • ,
! 1,1.2.2-Tetrachloroethane
I Toxaphene
•
Acenaphthene
Diethyl phthalate
_
Di-n-butylphthalate
Butylbenzylphthalate
N-Nitrosodiphenylamine
Fluorene
Hexach lorobutadiene
Pentachlorophenol
2.4.6-Trich lorophenol
•
Naphthalene
j 2-Chloronaphthalene
**~ —
2-Naphthylamine
2.4-D
1 -2-DichIorobenzene
SW-846
Method
8260B
8260B
8260B
8260B
———__.
8260B
8260B
8081A
Alternate Analytical
Method
8260B"
350.1350.3
-------
Table 1. Initial Baseline Organic and Inorganic Contaminants of Concern.
(6 sheets)
• CAS#
95-57-8
95-70-5
95-95-4
98-82-8
98-86-2
98-95-3
99-65-0
|
„ ... , SW-846
Constituent ... .. .
Method
'•
2-Chlorophenol 8270C
2.5-Diaminotoluene
2.4.5-Trich!orophenol 8270C
(!-MethylethyI)benzene 8260B
Acetophenone 8270C
Nitrobenzene 8270C
1.3-Dinitrobenzene 8270C
Alternate Analytical
Method
8270C
•'Analyte evaluated for Liquid Waste Processing Facility (LWPF) waste acceptance purposes
(FDNW 1998) and not as part of delisting assessment.
''Analyte will be reported as a tentatively identified compound (TIC).
CAS? = chemical abstract service number
Because the previous sampling did not provide a full characterization profile of the leachate. the
baseline characterization sampling program will provide a thorough quarterly analysis of the
leachate over a 1-year period. The first round of sampling to fully profile the leachate for
delisting has taken place. The results of this analysis were compared to the delisting levels
provided in Table 2 and it was determined that delisting could proceed.
Those COCs whose analytical results from baseline sampling indicate that their concentrations
are below 10% of the delisting level will be moved into a confirmatory sampling regimen.
COCs detected at concentrations greater than 10% of the delisting level may be monitored on a
routine basis at the discretion of the U.S. Environmental Protection Agency (EPA). COCs that
are not detected above 10% of the delisting level are considered to be below regulatory concern.
Confirmatory sampling will take place every 2 years, and routine sampling will take place every
6 months after the first year.
A determination as to delisting has been made by the EPA based on the results of the initial
characterization sampling. Since the results of the initial analyses indicate that the COCs do not
exceed the delisting levels, the U.S. Department of Energy (DOE) will manage the leachate as a
nonhazardous waste. Characterization sampling will continue for 1 year to establish baseline
analyte concentrations for the leachate. This sampling will consist of quarterly sampling for all
of the analytes listed in Table 1. In addition, samples may be collected in the midpoint of every
quarter for the routine sample analytes reported at greater than 10% of the delisting level in the
initial sample results at the EPA's discretion.
-------
Table 2. ERDF Delisting Levels and Comparison to Baseline Analytical Results.
(5 sheets)
CAS#
( 100-25-4
ll 00-4 1-4
j 100-42-5
100-51-6
1024-57-3
105-67-9
106-46-7 •
106-50-3
106-93-4
107-02-8
107-05-1
107-06-2
107-13-1
108-05-4
108-10-1
Constituent
jl.4-Dinitrobenzene
Ethyl benzene
Styrene
Benzyl alcohol
Heptachlor Epoxide
Delisting
Level"
240
1680000
2400
240000
4.8
2.4-Dimethylphenol 1 |680o
1 .4-Dichlorobenzene
p-Phenylenediamine
Ethylene dibromide
Acrolein
96
168000
1.2
16800
3-Chloropropene (Allyl chloride) | 95
1.2-Dichloroethane
—
Acrylonifrile
Acetic acid vinyl ester (Vinyl acetate)
4-Methyl-2-pentanone (MIBK)
1 08-60- 1 Bis(2-Chloroisopropyl) ether
108-88-3
(108-90-7
108-95-2
10-86-1
1 1 1-44-4
117-81-7
117-84-0
20-12-7 t
20-82-1
120-83-2 ;
22-39-4 l>
122-66-7 ]
23-91-1
24-48-1 E
26-98-7 2
Toluene
Chlorobenzene
Phenol
Pyridine
Bis(2-chloroethyl) ether
Bis(2-ethylhexyl) phthalate
Di-n-octylphthalate
\nthracene
,2,4-Trichlorobenzene
!.4-DichlorophenoI
^.N-Diphenylamine
,2-Diphenylhydrazine
.4-Dioxane
)ibromochloromethane
-Methyl-2-propenenitrile (Methacrylonitrile)
120
4.8
Primary
Sample*1
IOU
Duplicate |
Sample1" ;
KK I
5 L 5 I
f_ ,
5f | 51: i
IOU
.05 U
IOU
10 UJ
IOU
IOU
20 U
IOU
5U
5U
960000 | 10 U
48000
24
24000
2400
480000
960
1.92
144
16800
240000
1680
2400
21600
2.4
192
24
96
IOU
IOU
5U
5U
IOU
IOU
IOU
IOU
IOU
IOU
10 UJ
IOU
IOU
IOU
IOU
5U
IOU
10 L
.05 L ^
10 L' i
IOU
IOU
10 U
20 U
IOU
5U
5U
IOU
.10 U
IOU
5V
5 U
IOU
IOU
IOU
IOU
IOU
10 U
10 UJ
IOU
IOU
IOU
IOU
5 U
10 U
—1
-i
-------
Table 2. ERDF Delisting Levels and Comparison to Baseline Analytical Results.
(5 sheets)
CAS#
127-18-4
129-00-0
131-11-3
1319-77-3
1330-20-7
I"1 ^ £. "* £. "*
J JO-JO-J
141-78-6
14797-55-8
1 56-59-2
1 56-60-5
16984-48-8
193-39-5
205-99-2
206-44-0
207-08-9
218-01-9
309-00-2
3 1 9-84-6
319-85-7
50-00-0
50-29-3
50-32-8
51-28-5
53-70-3
541-73-1
542-75-6
56-23-5
56-55-3
57-12-5
58-89-9
59-50-7
Constituent
1 . 1 .2.2-Tetrachloroethene
Pyrene
Dimethyl phthalate
Cresols. total
Xylene
Polychlorinated biphenyls (PCBs)
Acetic acid ethyl ester (Ethyl acetate)
Nitrate
1 ,2-cis-Dichloroethene
1 .2-trans-Dichloroethene
Fluoride
lndeno( 1.2.3-cd)pyrene
Benzo(b)fluoranthene
Fluoranthene
Benzo(k)fluoranthene •
Chrysene
Aldrin
alpha-BHC
beta-BHC
Formaldehyde
4.4-DDT
Benzo(a)pyrene
2,4-Dinitrophenol
Dibenz[a.h]anthracene
1 ,3 - Dich iorobenzene
1,3-Dichloropropene
Carbon tetrachloride
Benzo( a (anthracene
Cyanide
Gamma-BHC (lindane)
4-Chloro-3-methylphenol
Delisting
Level"
120
24000
9600000
48000
240000
12
720000
240000
9600
16800
96000
5.04
1.704
24000
604.8
64.8
0.12
0.24
1.2
168000
•7 -i
4.8
1680
0.264
. 45360
12
120
1.848
4800
4.8
30240
Primary
Sample*3
5U
Duplicate
Sample"
5 r
10 U 101
10 U 1 101
10U
5U
2U
10U
1 30000 J
5U
. 5U
1400
.44 U
.18 U
10U
.17U
1.5 U
.05 U
.05 U
.05 U
12 UJ
.1 U
.23 U
25 U
.31 U
10 UJ
5U
5 U
.13 U
5U
.05 U
IOU
!OU
51'
2U "I
IOU 1
1 20000 J
5 U
5u ;
1 500
.44 U
.18 I
10 L
' .17U
1.5U
.05 U
.05 U
.05 U
12 UJ
.1 U
.23 U
25 U
.31 U
10UJ
5U
5 U
.13 L
10 L
.05 U
IOU
-------
Table 2. ERDF Delisting Levels and Comparison to Baseline Analytical Results.
(5 sheets)
CAS#
60-29-7
60-57- 1
621-64-7
62-50-0
62-53-3
62-75-9
67-56-1
67-64-1
67-66-3
67-72-1
70-30-4
71-36-3
71-43-2
71-55-6
72-20-8
72-54-8
72-54-8
7439-92-1
7439-96-5
7439.97-6
7440-02-0
7440-22-4
7440-28-0
7440-31-5
7440-36-0
7440-38-2
7440-39-3
7440-41-7
7440-43-9
7440-47-3
7440-48-4
Constituent
Ethyl ether
Dieldrm
N-Nitroso-di-n-propylamine
Ethyl methanesulfonate
Aniline
N-Nitroso-N.N-dimethylamine
Methyl alcohol
2-Propanone (Acetone)
Chloroform
Hexachloroethane
Hexachlorophene
n-Butyl alcohol
Benzene
.1,1 -Trichloroethane
Endrin
,4-DDD
.4-DDE
Lead
Manganese
Mercury
Nickel
ilver
Thallium
in
Antimony
Arsenic
Jarium
eryllium
admium
hromium
obalt
Delisting
Level*
168000
o.i:
0.24
0.0072
240
0.048
480000
96000
2400
144
240
96000
120
4800
48
9.6
7.2
360
2400
48
2400
4800
48
504000
144
1200
48000
96
120
2400
50400
Primary
Sample6
10 U
.1 U
10 U
10 U
10 U
10 U
6500 UJ
10 U
5 U
10 UJ
100 U
250 U
5U
5U
.1 U
.1 U
.1 U
1.8 U
.2U
.1 U
6.3 B
.9U
4B
2.7 U
2.3 U
14.9
64.6 B
.12U
.4U
14.1
.6U
Duplicate
Sample"
10 I
.1 L
10 i
10 U
1 0 L' !
10 U
6500 UJ
10 L i
5 u :
10UJ
100U
250 U
5U
5 U
.1 U
.1 L
.1 U
1.8 U
.2U
.1 U
6.1 B
.9 U
3.7U
2.7 U
2.3 U
14.4
64.2 B
.16U
.4U
15.7
.61)
10
-------
Table 2. ERDF Delisting Levels and Comparison to Baseline Analytical Results.
(5 sheets)
CAS#
7440-50-8
7440-62-2
7440-66-6
74-83-9
74-87-3
75-01-4
75-05-8
75-09-2
75-15-0
75-25-2
75-27-4
75-34-3
75-35-4
75-69-4
75-71-8
76-13-1
76-44-8
7782-49-2
78-59-1
78-83-1
78-87-5
78-93-3
79-00-5
79-01-6
79-34-5
8001-35-2
83-32-9
84-66-2
84-74-2
85-68-7
86-30-6
Constituent
Copper
Vanadium
Zinc
Bromomethane
Chloromethane
1 -Chloroethene { Vin\ 1 Chloride)
Acetonitrile
Dichloromethane (Methylene Chloride)
Carbon disuifide
Tribromomethane (Bromoform)
Bromodichloromethane
1.1-Dichloroethane
1.1-Dichloroethene
Trichlorofluoromethane
Dichlorodifluoromethane
1.2.2-Trichlorotrifluoroethane (Freon 1 13)
Heptachlor
Selenium
Isophorone
2-Methylpropyl alcohol (Isobutyl alcohol)
1 ,2-Dichloropropane
2-Butanone (MEK)
1 , 1 .2-Trichloroethane
1 . 1 ,2-Trichloroethylene
1 . 1 .2,2-Tetrachloroethane
Toxaphene
Acenaphthene
Diethyl phthalate
Di-n-butylphthalate
Buty Ibenzylphthalate
N-Nitrosodiphenylamine
Delisting
Level1
31200
7200
240000
1200
808.8
48
4800
120
96000
2400
33.6
21.6
168
240000
168000
24000000
2.4
1200
2160
240000
120
480000
120
192
9.6
72
48000
720000
96000
168000
480
Primary
Sample"
6.4 U
25.9 B
1 U
10 U
10 U
10U
20 U
3 BJ
5U
5 U
Duplicate
Sampleb
' (xT
26.3 B'
.8 I"
10 I'
10 L
10 u :
20 U :
2BJ i
5 U ;
5L
5U | 5U
5U
5 U
5 U
10U
10 U
.05 U
3.6 U
10 U
100 U
5U
10 U
5U
5 U
5U
5 U
10 U
10 U
.5 J
10 U
10 U
5 U
5 f
5 U
10 L
10 U
.05 U
3.6 L
10 U
100U
5 U
10 U
5 U
5 L"
5 L
5 L
101'
10 L
.5 J
10U
10 L
11
-------
Table 2. ERDF Delisting Levels and Comparison to Baseline Analytical Results.
(5 sheets)
CAS#
86-73-7
87-68-3
87-86-5
88-06-2
91-20-3
91-58-7
91-59-8
94-75-7
95-50-1
95-57-8
95-70-5
95-95-4
98-82-9
98-86-2
98-95-3
99-65-0
Constituent
Fluorene
Hexachlorobutadiene
Pentachlorophenol
2.4.6-Trichlorophenol
Naphthalene
2-Ch loronaphthalene
2-Naphthylamine
2.4-D
1.2-Dichlorobenzene
2-ChIorophenol
2.5-Diamintoluene
2.4,5-Trichlorophenol
( I-Methylethyl)benzene
Acetophenone
Nitrobenzene
1.3-Dinitrobenzene
Delisting
Level"
24000
24
16.8
192
24000
72000
2.4
1680
14400
4800
230400
96000
24000
96000
480
96
Primary
Sample"
10 U
10 UJ
25 U
10 U
10 U
10 UJ
10U
Duplicate
Sampleb
10 I
IOLJ
25 L
10 L
101
10UJ
10 L
i u .; i r
10UJ
10U
ND
25 U
ND
10U
10U
10 U
IOUJ
10 U
ND
25 U
ND
10 U
10 U
10 U
"Delisting level = 24 times the docket value.
''Sampling event of January 12, 1999. All values reported in ug/L.
B = qualifier denotes the analyte was detected in the associated quality control (QC) blank and in the
sample
CAS£ = chemical abstract number
J = qualifier denotes estimated value
ND - not detected
U = qualifier denotes not detected
After the first year, sample collection and analysis will move into the routine sampling program.
Routine sampling will take place every 6 months. At the direction of the EPA, analyses will be
conducted for all COCs identified in the characterization samples at levels greater than 10% of
the delisting level. Analyses will also be performed for physical parameters and other
constituents required by the ETF. Every 2 years, samples will be analyzed for the full suite of
COCs identified in Table 1 unless otherwise agreed to by the DOE and EPA.
Several constituents identified as potentially being used on the Hanford Site have neither a
docket value nor applicable health-based exposure limit. These constituents are listed in Table 3.
If any of the chemicals listed in the table are detected in the leachate, further assessment will be
done by the DOE and EPA to determine if further action needs to be taken.
12
-------
Table 3. Potential Contaminants With No Delisting Levels.
CAS#
•100-02-7
Constituent
Concentration Detected
in Leachate *
4-Nitrophenol 25 U
101-55-3 >4-Bromophenylphenyl ether 101'
106-99-0 1.3-Butadiene ND
[109-99-9 Tetrahydrofuran (THF - furan indicator) ND
i 110-75-8 ;2-Chloroethyl vinyl ether . 10 U
•111-91-1 'Bis(2-Chloroethoxy)methane 10 U
1 126-68-1 iO.O.O-Triethyl phosphorothioate NA
•131-89-5
134-32-7
14265-44-2
14797-65-0
14808-79-8
2-Cyclohexy!-4.6-dinitrophenol ND
alpha-Naphthylamine . 10 U
Phosphate
Nitrite
0.12
5000 UR
Sulfate 338000
1634-02-2 Tetrabutylthiuram disulfide
16887-00-6 iChloride
22781-23-3 Bendiocarb
-
443000 :
NA
.24959-67-9 , Bromide
2800
26545-73-3
57-97-6
59-89-2
591-08-2
7429-90-5
7439-95-4
7440-21-3
75-00-3
75-70-7
Dichloropropanol i ND
7. 1 2-Dimethytbenz[a]anthracene 1 0 U
N-Nitrosomorpholine 10 U
l-Acetyl-2-thiourea | ND
Aluminum 21.5 U
Magnesium 47800
Silicon 17000J
Chloroethane 10 U
Trichloromethanethiol ND
7664-41-7 Ammonia 100U
"All results in ug/L except where noted.
CAS« = chemical abstract services number ND
J = qualifier denotes estimated value R
NA = not analyzed U
: not detected
: result unusable
: qualifier denotes not detected
13
-------
1.2.1 Non-Delisting-Related Test Parameters
Physical parameters, radionuclides. and some inorganic constituents will be tested that do not
relate to delisting of the leachate. The LWPF requires certain physical testing of incoming
effluent per the facility's acceptance criteria (FDNW 1998). The following analyses are added to
the test list for the general water quality information to support characterization requirements for
the ETF:
• pH • Gross alpha
• Specific conductance • Gross beta
• Total dissolved solids • Gamma scan
• Total organic carbon • Potassium
• Total suspended solids • Calcium
• Oil and grease • Sodium.
1.2.2 Rationale
Several factors may contribute to the variability of leachate analytical results and should be
considered when determining the frequency of sample collection. Factors that may affect
chemical, physical, and biological processes occurring within the facility include seasonal
variations, waste stream, configuration of ERDF, and operational changes that may occur over
time. Seasonal variations in temperature and precipitation may affect the composition of the
leachate.
Seasonal and annual climate changes can significantly affect the volume of leachate generated at
the ERDF. Beginning in July 1996. ERDF generated approximately 6.435.180 L
(1.7 million gal) of leachate from disposal cell 1. During the second year of operation beginning
in July 1997. ERDF generated approximately 1.514,160 L (0.4 million gal) of leachate from the
combined operation of cells 1 and 2. The large difference in leachate generation between the
two years is primarily a result of differences in precipitation and the amount of waste in the cells.
The yearly total precipitation for the 1996-1997 operation was 28.9 cm (11.4 in.): for 1997-1998
the total was approximately 16.3 cm (6.4 in.). For comparison, the average annual precipitation
from 1947 through 1997 has been 17.34 cm (6.83 in.). Figure 1 illustrates the average
precipitation values at the Hanford Site for the past 50 years. Based on average precipitation.
ERDF would be expected to collect from 757.080 to 1.135,620 L (0.2 to 0.3 million gal) of
leachate per operating disposal cell per year, with a maximum annual leachate generation rate
approaching 13,248.900 L (3.5 million gal). ERDF is expected to have up to three disposal cells
operating at one time after an expansion, which could generate 2,271,240 to 3.406.860 L (0.6 to
0.9 million gal) annually during years of average precipitation. However, the leachate generated
could be substantially more during years of high precipitation, as experienced in 1995 and 1996
(31.3 and 30.9 cm [12.31 and 12.19 in.], respectively). Leachate generation is enhanced when
there is little waste in the cell, because the waste serves to retard the infiltration. Smaller
volumes of waste in a cell results in faster conversion of precipitation to leachate. due to shorter
travel time through the soil column. Smaller volumes also result in less surface contact of pore
water with wastes and. therefore, less potential for contamination in leachate. Should leachate
volume approach the maximum on an annual basis, the appropriate action will evaluated in
coordination with EPA.
14
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Figure 1. Hanford Site Annual Precipitation Values, 1946-1997.
Annual Precipitation
14
12
10
c
o.
u
£
Q.
,&> A t?> <& <"$* <& «?> «?> «3- «j!» C?> «?> A51 A^- A^ Afc A* <&• <*k 9iP <& <& <& oS* C&
,°r .of* ^S3 .CS3 ^^ ^ ^ N^ ^ s*1 N# ^ ^V N^ N^ ^ Nc#> ,c?> Nc?> sc?> Nc£> f?> ^> ^ ^>
Year (Ave. 6.83 inches)
The "wet" season at the Hanford Site typically occurs between November and February, which
also generally corresponds to the coldest months of the year. June through September are
typically the driest months, which correspond to the warmest weather months. The proposed
sampling program is expected to be capable of characterizing any seasonal variations. If
experience shows that only limited volumes of leachate are generated or shipped in dry months.
the sampling program will be evaluated to consider grab samples for this time period.
The ERDF Record of Decision (ROD) (EPA 1995b) authorizes the construction of two disposal
cells: a ROD amendment (DOE-RL 1997) authorizes the construction of two additional cells. As
new cells are constructed and full cells are capped, the volume and composition of the leachate
may be affected by variations in the waste matrices exposed to precipitation (i.e., waste within a
capped cell may not generate as much leachate. and a cell that is open but not receiving waste
will generate "cleaner" leachate than a cell actively receiving waste). It is difficult to determine
the effects on the leachate of a different configuration of the facility; however, the proposed
sampling is expected to be frequent enough to identify any changes that may be attributed to
variations in open cells. In addition, mixing within the leachate storage units provide a buffer
that reduces the variability associated with leachate from different cells. Therefore, additional
sampling is not proposed when the configuration of the facility changes.
15
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The final factor considered for its effects on the leachate is operational changes at the ERDF.
Such changes may include the amount of liquid used for dust suppression and compaction, and
opening a new cell for waste placement. Removal of the floating covers from the storage units
or redesign of the leachate storage facility could result in higher evaporation rates, concentrating
some COCs in the leachate. The proposed sampling plan will accommodate this variabilin.
ERDF may accept waste from different areas within the Hanford Site, but generally only
receives waste from a subset of areas over a period of months. The waste matrix, as well as the
COCs associated with the waste, may influence leachate concentrations. Therefore, at least
semi-annually. the waste matrix will be evaluated by the project engineer for variability. If
waste matrices not previously received enter the facility, the monitoring program will be
evaluated to consider the regulated contaminants of potential concern that are defined in the
waste profile, but are not currently being monitored. This evaluation will include risk drivers, as
identified in the docket list, that are placed in the ERDF in significantly greater volumes than
previously disposed at ERDF. It is anticipated that the proposed sampling approach will be
sufficient to monitor any changes in leachate concentration that may be affected by the waste
matrix.
1.2.3 Sampling Strategy
The leachate that is stored in the disposal cell sumps and holding tank(s) is considered to be
representative of liquids that have been generated from the ERDF for a period of time. The
purpose of the sampling and analysis is to ensure proper delisting status of the leachate.
Delisting will allow the leachate to be stored and conveyed to the LWPF without having to be
managed as a hazardous waste. Sampling must accomplish the dual goal of characterizing the
leachate to ensure that it continues to meet delisting criteria and provide data to support treatment
at the LWPF. Because the leachate is being stored for transfer to LWPF, characterizing the
leachate so as to provide a representative sample is the primary analytical objective. There are
three primary sampling designs that will meet the objective: 1) composite samples from the
leachate storage units. 2) composite samples from the leachate sump crest pads, and 3) composite
sample from an automatic flow-proportional device in the leachate pump station.
Normally a composite sample will be taken from the storage units or the crest pads. However.
during times of high leachate generation, a flow-proportional device will be used to collect
representative leachate samples for all monitored compounds except volatile organics and oil and
grease. At a minimum, a grab sample will be collected for volatiles and oil and grease analysis
when a composite sample from the flow-proportional device is retrieved for analysis.
Flow-proportional samples will present a volume-averaged profile of the leachate during
high-flow periods. A flow-proportional sampling device has been installed in-line between the
storage tanks and the discharge point to the pipeline for transfer to LWPF or to tanker trucks.
Over time, compounds may be placed in the ERDF that have not been evaluated through
previous analysis of the leachate. Profiles of waste streams that had not previously been placed
in the ERDF will be evaluated for the presence of compounds that are not on record as being
contained in ERDF wastes. These compounds will be evaluated against the initial list of COCs
(Table 1) to determine whether constituents are regulated, are in sufficient quantity to warrant
investigation, can be analyzed for. and are identified as a risk driver on the EPA docket list.
16
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Compounds, that remain after this screen (a similar process that was used to develop the initial
COC list) will be evaluated for testing in the routine sampling program. If. after 1 year, the
compound is not detected above the 10% delisting level, the compound will be eliminated from
the routine monitoring list.
1.3 PROJECT ORGANIZATION AND RESPONSIBILITY
This section provides the organizational and project roles and responsibilities for sample
collection, laboratory analysis, data management, and data assessment for ERDF leachate
characterization and monitoring activities.
1.3.1 Project Responsibility
Site Technical Representative: The Environmental Restoration Contractor (ERCVERDF Site
Technical Representative (STR) will coordinate efforts of support organizations as needed to
complete the required tasks. The STR also determines the timing and volume of leachate
transfers.
ERC/ERDF Project Engineer: The ERC/ERDF project engineer will direct and approve all
technical aspects of the leachate characterization. Responsibilities include leachate flow volume
calculations for programming of the automatic sampler to ensure that collected samples are
representative of the leachate. and assessment of incoming waste profiles to evaluate any need
for additional analysis.
ERC/ERDF Project Environmental Lead: The ERC/ERDF environmental lead will interface
with the regulators to ensure that the characterization objectives for the leachate are consistent
with regulatory requirements.
ERDF Project Technician: An ERDF technician will inspect the automatic sampler, document
the inspections in the field logbook, and interface with ERDF operations and sampling support
groups to ensure that the sampler functions as required.
1.3.2 Support Responsibilities
The following organizations will be responsible for performing all services to the ERDF project
in accordance with the requirements in this SAP.
Sample Management: Sample Management will coordinate the sampling, laboratory services.
data reporting, and data validation for leachate characterization. Additional responsibilities
include handling and storage of deliverables generated through the process.
Project Chemist/Sample Coordinator: The chemist will ensure that validation is performed by
qualified validators that may be ERC or qualified subcontractors. The chemist will assess the
analytical data after validation and compare it to the warning levels (10% of the delisting level)
and delisting levels. The chemist will coordinate with the project engineer to ensure that
analytes are added to and removed from the sampling program.
17
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Analytical Field Services: Analytical Field Services will provide qualified samplers to program
the flow-proportional sampler, based on projected flow rates provided by the project engineer, as
required. Field Services will collect, package, and ship leachate samples to the laboratory.
Data Management: Data Management will provide access to information stored in the Hanlbrd
Environmental Information System (HEIS) database.
Data Assessment: A statistician and the project chemist will assess the data for trends and
perform statistical analysis after the first year of data collection, and on an ongoing basis, to
evaluate trends in leachate quality.
ERC Quality Programs: ERC Quality Management will provide quality assurance (QA)
assessments and surveillances.
1.4 SAMPLE COLLECTION
This section provides the requirements for collecting, packaging, and shipping leachate samples.
Sample collection will be performed in accordance with this SAP and approved ERC procedures.
1.4.1 Sample Collection Techniques
Representative samples may be collected and composited from leachate storage units or the crest
pads at leachate sump locations. Samples will be collected from leachate access ports or by use
of portable or dedicated pumps. Care will be taken to ensure no contaminants are introduced by
the sampling equipment being used.
An automatic sampler will be used to collect representative flow-proportional composite samples
of the leachate during periods of high-volume flow. The flow-proportioned samples will be
based on equal increments of flow as measured by an associated flowmeter. The flowmeter is
installed to measure the volumes of leachate pumped from the modu-tanks to the LWPF. The
automatic sampler will be installed downstream of this flowmeter. The composite sample will
be analyzed for all monitored compounds except volatile organic analytes (VOA) and oil and
grease. A grab sample will be collected for VOA analysis and the oil and grease analysis when
the composite sampler is used. A grab sample may be collected for all analytes as appropriate.
1.4.2 Sample Volume, Preservation, and Holding Times
The volume of sample collected depends upon the type and number of analyses needed, as
reflected in the parameters to be measured and the requirements of the analytical laboratory ,
being used. Sample volume must be sufficient for all analyses, including laboratory QA/QC.
Several analytes may be analyzed by one of two methods requiring different volumes; therefore.
the total volume depends on the methods selected. The total composite volume required for
analyses is approximately 13.2 L (3.5 gal). Final sample volumes will be specified in the SAF:
SAP procedures are found in BHI-EE-01. Environmental Investigations Procedures, EIP 2.0.
"Sample Event Coordination." Table 4 lists the analytical methods, preferred volumes, and a
prioritized list of methods for analysis in the event of insufficient sample collection for analysis
of the complete list of COCs. Sample analyses were prioritized based on multi-analyte methods
and higher health-risk associated analytes.
18
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Table 4. Sampling and Holding Time Requirements for the Contaminants of Concern
Analytical Methods. (2 Sheets)
Analytical T.^,
., :, , • Title
Method |
i
Preferred
Sample
Volume
Total
Sample
Volume,
QC
included
Container
! Hold Time • Priority
Preservation 'sampline! Prep to
to Prep , Analysis
Composite Sample
60IOB iInductively Coupled Plasma- ; 100 ml. 300 mL Glass or plastic II\O3 to pH- 2
lAtomic Hmission j :
[Speetrometry : ! !
i "M70A Mercury in Liquid Waste
(Manual Cold Vapor
•Technique)
8070A' Nitrosamines by GC
8081. A 'Oraanochlorme Pesticides hv
8082 GCPCBsby GC
8 1 5 1 A ,'Chlonnated Herbicides by GC
I 'sing Methylation or
! Poniafluorobenzy lation
Derivatization: Capillary
[Column Techniques
8270Cb Semivolatile Organic
Compounds by GC/MS
L ._.
83 1 5 A* I Determination of Carbonyl
iCompounds by HPLC
: 8310" iSolvemExtractabiePAHs
i HPLC with UV and/or
.fluorescence
83 1 8 (N-Methy Icarbamates by HPLG
i
!
90 1 OB Total and Amenable Cyanide
i( Distillation/ Automated
iColorimetric)
i
9056 j Determination of Inorganic
iAnions by Ion
! 100 mL
1 L
1
: 1 L
1 L
1 L
lOOfnL
1 L
lOOmL
500 mL
lOOmL
300 mL
i 3L
1 3L
3 L
.
3L
300 mL
3L
300 mL
l.SOOmL
lOOmL
Glass or plastic
Amber glass
with Teflon-
lined lid
Glass. Teflon-
lined cap
Amber glass
with Teflon-
lined lid
Amber glass
with Teflon-
lined lid
Glass. Teflon-
lined cap
Glass. Teflon-
lined cap
Amber glass
with Teflon-
lined lid
Glass or plastic
Glass or plastic
;HNO3topH<2
:Cool.4°C
:Cool. 4°C
Cool. 4CC
I Cool. 4°C
Cool. 4°C
Cool. 4=C
Cool. 4=C. adjust
pH 4-5 with O.I N
chloroacidic acid
Cool. 4°C: if
oxidizing agents
present add 5 mL
0.1NNaAsO2
per L or 0.06 g of
ascorbic acid per
L; adjust pH> 12
with IO%NaOH |
Cool. 4°C
28da\s 5
7 days 40 days 2
7 days 40 days 4
7 day s : 40 day s . 1 .o\\ er
priority
7 days 40 Ua> s . 1
3 days 3 days Loner
priority
7 days : 40 days' Los\er
priority
~ da\s 41) da\ •• 1 ovvjr
priority
1 4 day s j 6 :
i
i
48 hr
9060
9050A
Total Organic Carbon
Specific Conductance
. 100 mL
lOOmL
lOOmL
lOOmL
Glass j Cool. 4°C: adjust
ipH<2 with HCI
;orH2SO4
Glass or plastic ;Cool. 4°C
28 days I Lower
. priority
28 days Lower
priority
Teflon is a trade name of E. I. duPont de Nemours and Company. Wilmington. Delaware.
19
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Table 4. Sampling and Holding Time Requirements for the Contaminants of Concern
Analytical Methods. (2 Sheets)
Analytical
Method
1 9040
Title
pH Electrometnc
Measurement
160 1 (Total Dissolved Solids
1602
350,2
(distill)
followed
b\ 3501
or 350,3
Total Suspended Solids
Ammonia
Total Volume for Composite
Sample"
Preferred
Sample
Volume
Total
Sample
Volume,
QC
included
lOOmL : lOOmL
I
i '
i
Container Preservation
Glass or plastic jCool. 4°C
!
100 mL | 300 mL Glass or plastic Cool. 43C
lOOmL 300 mL Glass or plastic Cool. 4°C
400 mL
5.4-
6.5 L
1.200 mL Glass or plastic Cool. 4CC. adjust
ipH<2 with
JM2SO4
Hold Time Priorit>
i
Sampling' Prep to ;
to Prep Anahsis .
Analw.e S
immediately
" da>s Lower
pnont>
7da\s Lower
priori!)
28 da>^ 1 ower
priorii-
13.9-
17.2 L j
* i " ,
Grab Sample
6252.-V
'
'
: 8015
8260B
9030B'
9034 or
9215
9070
I
PFBHA liquid-liquid
extraction by GC method
Alcohols b\ GC
Volatile Organic Compounds
b> GC'MS
Sulfide by distillation followed
by Colorimetric or ISE
Total Recoverable Oil and
Grease (Gravimetric.
Separatory Funnel Extraction)
Total Volume for Grab
Sample"
2 x 40 mL
2 x 40 mL
2 x 40 mL
250 mL
1 L
1.41-
1.49 L
6 x 40 mL
6 x 40 mL
6 x 40 mL
500 mL
31.
3.98-
4.22 L
40-mL glass
vial with
Teflon-lined
septum caps
40-mL glass
vial with
Teflon-lined
septum caps
40-mL glass
vial with
Teflon-lined
septum caps
Glass or plastic
Glass
Cool. 4°C
Cool. 4°C
.
Cool. 4°C. adjust
pH<2 with
HsSO4. HC1. or
solid NaHSO4
Cool. 4°C; add
zinc acetate per
1 00 mL. adjust
pH> with NaOH
Cool. 4°C. adjust
pH<2withHCI
48 hours Lower
priori!)
14da\s .>
I4da\s 2
!
i
!
! i
7 days i 6 !
•
•
28 da>?> I.o\\oi
pnoni\
'Nitrosammes may be analyzed by 8070A or 8270C depending on which method will achieve detection limits in Table 5.
bPAHs mas be analyzed by either 8270C or 8310 provided that practical quantitation limits in Table 5 are met.
sEilher method may be used for formaldehyde.
"Volume depends on methods selected. •
GC = gas chromatographv
HPLC s high performance liquid chromatography PAH = polycyclic aromatic hydrocarbon
JSE " ton-selective electrode PCB = polychlorinated biphenyl
MS = mass specirometry UV = ultraviolet
20
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Sample preservation ensures the sample remains representative of the leachate from the time of
collection until the time of analysis. Sample preservation techniques consist of refrigeration and
pH adjustment. Because sample deterioration can take place during the flow-proportional
sample compositing process, it will be necessary to refrigerate these samples during compositing.
in addition to preserving any aliquot samples before shipment to the laboratory. Samples will be
refrigerated to 4° * 2°C when composited to decrease the potential for chemical degradation.
After samples are aliquoted into bottles for specific analyses, samples will be preserved per
Table 4. Refrigeration continues using wet ice (or equivalent) during sample shipment and until
the sample is received in the laboratory for analysis. Final sample preservation requirement* \\ili
be specified in the SAP and are shown in Table 4.
In addition to preservation techniques, holding times between sample collection and analysis
must be met for the sample data to be considered valid. The leachate composite becomes a
sample upon collection or the removal of the sample from the flow-proportional container. At
that point, holding time limitations begin. Final sample holding times will be specified in the
SAP and are shown in Table 4.
1.4.3 Sample Documentation
All information pertinent to field sampling and analysis will be recorded in bound logbooks in
accordance with BHI-EE-OL EIP 1.5. "Field Logbooks." Entries made in the logbook will be
dated and signed by the individual who makes the entry.
1.4.4 Sample Identification and Labeling
The Hanford Sample Data Tracking database will be used to track the sample and laboratory results.
Sample numbers will be issued to the sampling^rganization in accordance with BHI-EE-01.
EIP 2.0. Each sample will be identified and labeled with a unique sample number. The sample
location, date, and time of collection along with the corresponding number will be recorded on
the chain-of-custody form and in the field sampling logbook.
Each sample container will be labeled with the following information using a waterproof marker
on firmly affixed, water-resistant labels:
• Sample number
• Sample collection date/time
• Name/initials of sampler
• Analysis required
• Preservation method, if applicable.
1.4.5 Chain-of-Custody Procedures
All samples will be controlled from the point of origin to the analytical laboratory in accordance
with BHI-EE-01. EIP 3.0. "Chain of Custody." A chain-of-custody record will be initiated in the
field at the time of collection and will accompany each set of samples. Chain-of-custody
procedures will be followed throughout the sample collection, transfer, analysis, and disposal to
ensure that the integrity of the sample is maintained.
21
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A custody seal (evidence tape) will be affixed to the lid of each sample container. The custod>
seal will be initialed and dated by the sampler at the time the container is sealed.
1.4.6 Sample Packaging and Shipping
Samples will be packaged and shipped in accordance with BHI-EE-01. EIP 3.1. "Sample
Packaging and Shipment." After the samples are properly labeled, they will be placed in a
transportation package along with the chain-of-custody and sample analysis request form.
Samples will be placed in sufficient ice to maintain the temperature at 4° ± 2°C throughout the
shipment.
Most samples will not require any special transportation precautions except careful packaging to
prevent breakage and/or spillage. The sample shipment must comply with applicable
U.S. Department of Transportation Hazardous Materials Regulations (49 CFR 171-177) and
International Air Transport Association air shipment requirements.
1.5 SAMPLING QUALITY ASSURANCE AND QUALITY CONTROL
Quality assurance requirements for sampling are established in BHI-QA-03. Quality Assurance
Program Plans. Procedure 5.1. "Field Sampling Quality Assurance Program Plan." All
sampling personnel will be sufficiently trained to ensure the acquisition of complete and
high-quality data.
t
1.5.1 Equipment Operation and Calibration
All sampling and field measurement equipment used to support this project will be calibrated to
operate within the specifications provided by the manufacturer and in accordance with applicable
ERC procedures. Calibrations will be performed as stipulated by the manufacturer's calibration
procedure, the project-specific calibration requirements, or as specified within the requirements
defined by the analytical method.
1.5.2 Preventive Maintenance
All measurement and testing equipment used in the field that directly affects the quality of the
analytical data is subject to preventive maintenance measures that ensure minimization of
measurement system downtime.
Analytical Field Services will be responsible for maintenance of the sampling equipment
(including the flow-proportional sampler) in accordance with manufacturers' recommendations.
An ERDF project technician will perform routine inspections of the equipment and notify
Analytical Field Services if problems occur with the equipment. Maintenance requirements.
such as parts lists and instructions, will be included in the operating procedure for the automatic
sampler. Field repair of the sampler may be limited to replacement of expendable items or
certain mechanical parts. Electronic parts must be repaired by a qualified technician who has
access to the proper test equipment, which may therefore require repair by the manufacturer.
22
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1.5,3 Field Quality Control Requirements
QC samples are introduced into the collection system to monitor the adequacy of the sampling
system and the integrity of the samples during their transfer from the field collection point
through the laboratory analysis. QC requirements for the field sample collection process are
defined as follows:
• When the composite flow-proportional sampler is used, one container rinsate blank u ill
be collected from the carboy for each new sampling event. The equipment rinsate blank
will assess the cleanliness of the sample container and the effectiveness of the container
decontamination process. The rinsate blank will be collected using American Society for
Testing and Materials (ASTM) Type II water passed through the decontaminated
sampling container prior to starting the next sampling event. The rinsate blank will be
analyzed for the same chemical constituents used to decontaminate the container (e.g..
acetone). All sample results will be evaluated to determine the possible effects of any
contamination that may be introduced by the sample collection container, as detected in
the rinsate blank.
The container rinsate blanks will be collected and submitted to the laboratory at the time_
of collecting the current composite sample; however, the analytical results will correlate
to the subsequent composite sampling event.
• One field duplicate sample of the leachate will be collected for each sampling event.
Field duplicates are composed of two samples produced from the same matrix and
collected at the same location. The field duplicates provide information concerning the
homogeneity of the matrix, as well as an evaluation of the precision of the sampling and
analysis process.
When the sampling event cycle is completed, and aliquots are prepared for the individual
sample analyses, equal aliquots will be assigned to field duplicate samples.
• One VOA trip blank will be collected for every VOA sampling event. Trip blanks are
samples prepared by adding clean, analyte-free water to sample containers for analysis of
volatile organic compounds. Preservatives are added to the blank, and the containers are
sealed before the sampling trip. Trip blanks are usually prepared in the laboratory and
are transported with empty sample containers to the site of work and remain sealed until
analyzed with the collected samples at the laboratory. Trip blanks permit evaluation of
contamination generated from sample containers or occurring during the shipping and
laboratory storage process.
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1.6 LABORATORY ANALYSIS
1.6.1 Analytical Methods
Analytical methods will be as defined in Test Methods for Evaluating Solid Waste, Physical
Chemical Methods (EPA 1997). except for ammonia, total suspended solids (TSS). and total
dissolved solids (TDS)1. Ammonia. TSS. and TDS analytical methods are defined in Chemical
Analysis of Water and Wastes (EPA 1995a). Table 5 identifies analytes and the associated
method references and target detection limits identification for all COCs. Analyses will be
performed on unfiltered samples. Analyses are expected to be performed on and reported as
undiluted samples except for quantification of constituents exceeding the upper calibration limit
of the associated analytical method.
1.6.2 Detection Limits
Method detection limits (MDL). as defined in Chapter 1 of SW-846 (EPA 1997). will be used to
assess method sensitivity. The MDL is the lowest amount of the analyte that can be detected in a
sample, based on the analytical method. Laboratories report practical quantitation limits (PQL).
which is another term that is equivalent to the estimated quantitation limits (EQL). PQL EQL .
values typically are higher than the MDL and reflect levels that are routinely achieved in a
variety of sample matrices. Table 5 lists the analytes. the method, the delisting level (24 times
the docket value: see page 13 of accompanying ROD amendment), and the laboratory MDL.
The full spectrum analysis performed on the leachate includes a search for tentatively identified
compounds (TIC). Detection of TICs may be due to the presence of secondary chemical
breakdown products. Assessment of analytical results will include examination of any TIC
reported as part of the routine broad-spectrum volatile and semi-volatile organic analyses (gas
chromatograph — mass spectrum). The mass spectrum libraries, used to search for compound
identification of "unknown" analysis peaks, typically exceed 60.000 individual compounds.
Examination of reported TICs from periodic sampling will be the primary mechanism for
inclusion of any unexpected constituents in future sampling lists, regardless of the source of the
constituent. Potential sources could include residues from undocumented use or disposal of
chemicals, or decomposition of known materials used/disposed of at the Hanford Site.
Additionally, the laboratories currently under contract must prove that the laboratory can
satisfactorily perform any methods not typically performed under the existing contract
(e.g.. methods 83ISA. 6252B, 8310. 8070A).
24
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Table 5. Comparison of Deiisting Levels and Method Detection Limits
for the Contaminants of Concern. (6 Sheets)
CAS#
7429-90-5
7440-36-0
7440-38-2
7440-39-3
7440-41-7
7440-43-9
7440-47-3
7440-48-4
7440-50-8
7439-92-1
7439-95-4
7439-96-5
7440-02-0
7782-49-2
7440-21-3
7440-22-4
7440-28-0
7440-31-5
7440-62-2
7440-66-6
7439.97-6
72-54-8
72-55-9
50-29-3
309-00-2
3)9-84-6
319-85-7
60-57-1
72-20-8
58-89-9
76-44-8
1024-57-3
8001-35-2
1336-36-3
94-75-7
71-55-6
79-34-5
127-18-4
Constituent
Aluminum
Antimons
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Lead
Magnesium
Manganese
Nickel
Selenium
Silicon
Silver
Thallium
Tin
Vanadium
Zinc
Mercury
4.4-DDD
4.4-DDE
4.4-DDT
Aldrin
Alpha-BHC
beta-BHC
Dieldrin
Endrin
Gamma-BHC (lindane)
Heptachlor
Heptachlor epoxide
Toxaphene
Polychlorinated biphenyls (PCBs)
2.4-D
1,1.1 -Trich loroethane
1 , 1 .2,2-Tetrachloroethane
1 . 1 .2.2-Tetrachloroethene
Method ID
601 OB
6010B
601 OB
601 OB
601 OB
601 OB
601 OB
60 JOB
601 OB
601 OB
601 OB
601 OB
601 OB
601 OB
601 OB
601 OB
6010B
601 OB
6010B
601 OB
7470A
808 1 A
8081 A
8081 A
808 1 A
808 1 A
8081 A
8081 A
8081 A
8081A
8081A
8081 A
8081 A
8082
8151A
8260B
8260B
8260B
Deiisting
Level *
b
144
1200
48000
96
120
2400
50400
3120
360
b
2400
2400
1200
b
4800
48
504000
7200
240000
48
9.6
7.2
7.2
0.12
0.24
1.2
0.12
48
4.8
2.4
4.8
72
12
1680
4800
9.6
120
MDL*
31
-\
82
0.4
0.4
3.3
2.7
4.3
.. 4.1
30
5000
1
15
61
5000
6
3
35
2.9
2.3
0.03
0.0 1
0.01
0.01
0.01
o.ot
0.019
0.02
0.02
0.009
0.0 11
0.0 1
0.2
0.5-9.0
4
0.89
1.5
0.92
Comments
Depending on Arochlor
25
-------
Table 5. Comparison of Delisting Levels and Method Detection Limits
for the Contaminants of Concern. (6 Sheets)
CAS#
79-00-5
79-01-6
75-34-3
75-35--1
76-13-1
156-59-2
107-06-2
78-87-5
156-60-5
106-99-0
542-75-6
10061-01-5
10061-02-6
123-91-1
75-01-4
98-82-8
78-93-3
110-75-8
126-98-7
78-83-1
67-64-1
107-05-1
108-10-1
141-78-6
108-05-4
75-05-8
107-02-8
107-13-1
71-43-2
75-27-4
74-83-9
75-15-0
56-23-5
108-90-7
75-00-3
Constituent
1 . 1 .2-Trichloroethane
1 . 1 .2-Trichloroethylene
I.l-Dichloroethane
1.1-Dichloroeihene
1 .2.2-Trichlorotrifluoroethane
(Freon 113)
1 .2-cis-Dichloroethene
1.2-Dichloroethane
1 .2-Dichloropropane
1.2-trans-Dichloroethene
1,3-Butadiene
1 .3-Dichloropropene
cis- 1 .3-Dichloropropene
trans-1 .3-Dichloropropene
1.4-Dioxane
l-Chloroethene (vinyl chloride)
1 -MethylethyObenzene
2-Butanone (MEK)
2-Chloroethyl vinyl ether
2-Methyl-2-propenenitrile
methacrylonitrile)
2-Methylpropyl alcohol (isobutyl
alcohol)
2-Propanone (acetone)
3-Chloropropene (allyl chloride)
4-Methyl-2-pentanone (MIBK)
Acetic acid ethyl ester (ethyl
acetate)
Acetic acid vinyl ester (vinyl
acetate)
Acetonitrile
Acrolein
Acrylonitrile
Benzene
Bromodichloromethane
Jromomethane
Carbon disulfide
Carbon tetrachloride
Chlorobenzene
Chloroethane
Method ID
8260B
8260B
8260B
8260B
8260B
8260B
8260B
8260B
8260B
8260B
8260B
8260B
8260B
8270C
8260B
8260B
8260B
8260B
8260B
8260B
8260B
8260B
8260B
8260B
8260B
8260B
8260B
8260B
8260B
8260B
8260B
8260B
8260B
8260B
8260B
Delisting
Level '
120
192
21.6
168
24000000
9600
120
120
16800
b
12
12
12
192
48
24000
480000
b
96
240000
96000
96
48000
720000
960000
4800
16800
4.8
120
33.6
1200
96000
120
2400
b
IVIDL'
0.5
-1
1
0.97
10
0.51 •
0.72
1
5
10C
as isomers
0.51
0.29
10d
3.4
5
2.1
3.1
2.2
380
9.7
1.2
1
10
3.6
23.5
21.4
1.7d
0.84
0.5
1.4
0.74
0.71
0.75
1
Comments
*
MDL with 25 mL -1.7 |ag;L
,
,
26
-------
Table 5. Comparison of Delisting Levels and Method Detection Limits
for the Contaminants of Concern. (6 Sheets)
CAS#
67-66-3
"4-87-3
124-48-1
75-71-8
75-09-2
26545-73-3
100-41-4
60-29-7
106-93-4
67-56-1
71-36-3
100-42-5
108-88-3
75-25-2
75-69-4
75-70-7
1330-20-7
120-82-1
122-66-'
106-46-7
591-08-2
95-95-4
88-06-2
120-83-2
105-67-9
51-28-5
95-70-5
91-58-7
95-57-8
131-89-5
91-59-8
101-55-3
59-50-7
100-02-7
57-97-6
83-32-9
98-86-2
Constituent
Chloroform
Chloromethane
Dibromochloromethane
Dichlorodifluoromethane
Dichloromethane (methylene
chloride)
Oichloropropanol
Ethyl benzene
Ethyl ether
Ethylene dibromide
Methyl alcohol
n-Butyl alcohol
Styrene
Toluene
Tribromomethane (bromoform)
Trichlorofluoromethane
Trichloromethanethiol
Xylene
1 ,2.4-Trichlorobenzene
1. 2-Diphenylhydrazine
\ ,4-Dichlorobenzene
1 -Acetyl-2-thiourea
2,4.5-Trichlorophenol
2.4.6-Trichlorophenol
2.4-Dichlorophenol
2.4-Dimethylphenol
2.4-Dinitrophenol
2,5-Diaminotoluene
2-Chloronaphthalene
2-Chlorophenol
2-Cyclohexyl-4.6-dinitrophenol
2-Naphthylamine
4-Bromophenylphenyl ether
4-Chloro-3-methylphenol
4-Nitropheno!
7. 1 2-Dimethyibenz(a]anthracene
Acenaphthene
Acetophenone
Method ID
8260B
8260B
8260B
8260B
8260B
8260B
8260B
8260B
8260B
8015
8260B
8260B
8260B
8260B
8260B
8260B
826.0B
8270C
82' 'OC
8270C
8270C
8270C
8270C
8270C
8270C
8270C
8270C
8270C
8270C
8270C
8270C
8270C
8270C
8270C
8270C
8270C or
8310
8270C
Delisting
Level '
2400
808.8
24
168000
120
b
1680000
168000
1.2
480000
96000
2400
24000
2400
240000
b
240000
1680
2.4
96
b
96000
192
2400
16800
1680
2304000
72000
4800
b
2.4
b
30240
-b
b
48000
96000
MDL'
0.86
Comments
-i •;
0.33 ;
2.3
3.8
100'
1.3
10
0.34
5000
12.6
0.64
0.79
0.36
2
e
0.71
1.1
10
5
1000
0.76
1.2
1.2
0.79
2.3
1000C
1.4
1.2
100
4.4
1.9
1.1
2.1
4.4
0.5
3.4
.
1
To be measured as TIC
Degrades during extraction1
i
i
27
-------
Table 5. Comparison of Delisting Levels and Method Detection Limits
for the Contaminants of Concern. (6 Sheets)
CAS#
134-32-7
62-53-3
120-12-7
56-55-3
50-32-8
205-99-2
207-08-9
100-51-6
111-91-1
111-44-4
1 08-60-1
117-81-7
85-68-7
218-01-9
1319-77-3
95-48-7
108-39-4
106-44-5
53-70-3
25321-22-6
95-50-1
541-73-1
106-46-7
84-66-2
131-1 1-3
84-74-2
99-65-0
117-84-0
62-50-0
206-44-0
86-73-7
87-68-3
Constituent
Alpha-Naphthylamine
Aniline
Anthracene
Benzol a )anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo( k Jfluoranthene
Benzyl alcohol
Bis(2-Chloroethoxy)methane
Bis(2-chloroethyl) ether
Bis(2-Chloroisopropyl) ether
Bis(2-ethylhexyl) phthalate
Butylbenzylphthalate
Chrysene
Cresols. total
o-Cresol
m-Cresol
3-Cresol
Dibenz[a.h]anthracene
Dichlorobenzene
1 .2-Dichlorobenzene
1 ,3-Dichlorobenzene
1 ,4-Dichlorobenzene
Diethyl phthalate
Dimethyl phthalate
Di-n-buryiphthalate
1 .3-Dinitrobenzene
Di-n-octylphthalate
Ethyl methanesutfonate
7luoranthene
rluorene
rlexachlorobutadiene
Method ID
8270C
8270C
8270C or
8310
8270C or
8310
8270Cor
8310
8270C or
8310
8270C or
8310
1 8270C
8270C
8270C
8270C
8270C
8270C
8270Cor
8310
8270C
8270C
8270C
8270C
8270Cor
8310
8270C
8270C
8270C
8270C
8270C
8270C
8270C
8270C
8270C
82 ?OC
8270C or
8310
8270C or
8310
8270C
Delisting
Level "
b
240
240000
1.848
4.8
1.704
604.8
240000
b
1.92
24
144
168000
64.8
48000
48000
48000
48000
0.264
14400
45360
96
720000
9600000
96000
96
16800
0.00"2
24000
24000
24
MDL"
4.4
1 ~!
0.5
O.I*
0.05s
0.06s
0.2*
0.93
1.6
1.5
2
2.9
2.2
0.1s
10
0.97
10
0.69
0.05*
as isomers
1.2
1.3
1.4
1.6
1.3
1.6
3.8
1.8
3.3
0.3s
0.3*
0.89
Comments
•
28
-------
Table 5. Comparison of Delisting Levels and Method Detection Limits
for the Contaminants of Concern. (6 Sheets)
CAS#
67-72-1
70-30-4
193-39-5
78-59-1
122-39-4
91-20-3
98-95-3
621-64--
86-30-6
59-89-2
62-~5-9
126-68-1
87-86-5
108-95-2
106-50-3
129-00-0
110-86-1
109-99-9
50-00-0
22781-23-3
57-12-5
1634-02-2
24959-67-9
16887-00-6
16984-48-8
14797-55-8
14797-65-0
14265-44-2
Constituent
Hexachloroethane
Hexachiorophene
lndeno( 1.2.3-cd)pyrene
isophorone
N.N-Diphenylamine
Naphthalene
Nitrobenzene
,\'-:\'itroso-di-n-propylamine
N'-Nitrosodiphenylamine
N-Nitrosomorpholine
.\'-:\:itroso-.\'.:\'-dimethylamine
O.O.O-Triethy! phosphorothioate
Pentachloropheno!
Phenol
p-Phenylenediamine
Pyrene
Pyridine
Tetrahydrofuran (THF - furan
indicator)
Formaldehyde
Bendiocarb
Cyanide
Tetrabutylthiuram disulfide
PH
Specific conductance
Bromide
Chloride
Fluoride
N itrate
Nitrite
Phosphate
Method ID
8270C
8270C
8270C or
8310
8270C
8270C
8270C or
8310
8270C
8270Cor
80~ 0 A
8270C
8270C
8270Cor
8070 A
8270C
8270C
8270C
8270C
8270C or
8310
8270C
8270C
8315Aor
6252B
8318
901 OB
9030B or
376.1
9040
9050A or
120.1
9056 or 300.0
9056 or 300.0
9056 or 300.0
9056 or 300.0
9056 or 300.0
9056 or 300.0
or 365.2
Oelisting
Level "
144
240
5.04
2160
21600
24000
480
0.24
480
~ b
0.048
b
16.8
480000
168000
24000
960
b
168000
b
4800
- b
b
b '
b
b
96000
240000
b
b
MDL"
0.98
40
0.1*
1.4
5
0,3s
1.2
1.8
1.5
10
1.3
5
16
0.42
100
0.3s
0.96
10
5000C
0.01
3.1
500
0. 1 pH unit
0. 1 5 umhos/
cm
250
100
50
50
50
250
Comments
_
MDL SOW A 10.46 tig L>
MDL 80 ~0 A 10. 15 ug Lj
1
This compound is likeh to
dissociate to sulfide. Sulfide
analysis is specified.
29
-------
Table 5. Comparison of Delisting Levels and Method Detection Limits
for the Contaminants of Concern. (6 Sheets)
CAS#
14808-79-8
7664-41-7
Constituent
Sulfate
Ammonia
Total organic carbon
Oil and grease
Total dissolved solids
Total suspended solids
Method ID
9056 or 300.0
350.1 or 350. 3
9060 or 4 15.1
9070or413.1
160.1
160.2
Delisting
Level *
b
b
b
b
b
b
MDL'
250
30
530
500
4700
1000
Comments i
Distill b\ method 35U.I.
followed b\ anaKsis h%
either 350. 1 i colonmetric > or :
350.3 USE) ;
NOTE: italics indicate analytes where MDL is above or equal to delisting levels.
'Unless otherwise noted, all values are in fig/L. Blank space in delisting level column indicates none established.
b No delisting level is specified for these analytes and/or they were added to meet ETF waste acceptance criteria and are
not part of the delisting.
""MDLs are estimated based on compounds of similar functional groups. These compounds are not typically analyzed b\
the stated methods. Method validation will be done to determine if MDLs below the delisting level can be attained. .
JA layer purge volume will be anempted (25 mL instead of 5 mL). which should decrease MDL bv an order of magnitude.
This is estimated and will be verified before sample analysis.
'MDL will be estimated based on compounds of similar volatility and structure. No other technical information could be
found for this compound.
'Degradation and hydrolysis are discussed in method 8270C.
"MDL is based on method 8310.
ISE = ion-selective electrode
1.6.3 Volatile Organic Analysis
The following compounds have analytical detection limits above l/10th of the delisting levels
shown for SW-846 method 8260 in fable 5:
• Ethylene Dibromide
• Acrylonitrile.
Values reported as '"non-detected" ("IT qualified) results will normally be standard analysis
reporting limit values for these compounds, which are greater than the delisting level. If the
compound is actually detected, the result will be reported to lower limits (it is possible to
"identify" a compound at lower levels when present [resolved from background "noise"] than
when not present), as low as the MDL. The MDL will be below the delisting value, but will be
above 1/10th of the delisting value. Evaluation of alternative analytical techniques found no
methods capable of routinely reaching detection limits of 1/10 or less of the delisting value.
Analysis by method 8260 is the best available compromise at this time.
30
-------
For a limited number of compounds measured by method 8260, routine "non-detect" reporting
limit values may not meet l/10th of the delisting level, but will be below delisting levels. Such
compounds actually present in trace quantities (as explained above), will be detected belo\\ the
delisting level, nominally, to values below 1/10th of the delisting value. These compounds
include the following:
• 1.1.2.2-tetrachloroethane • 2-Methyl-2-propenenitrile
• 1.1 -Dichloroethane • Ally! Chloride
• L3-Dichloropropene isomers • Bromodichloromethane
• Vinyl Chloride • Dibromochlorometnae.
1.6.4 Semi-Volatile Organic Analysis
The following compounds have delisting levels near or below the analytical detection limits
shown for SW-846 method 8270 in Table 5:
• Bis(2-chloroethyl)ether • N-nitroso-di-n-proplyamine
• 1.2-Diphenylhydrazine • N-nitroso-n.n-dimethylamine
• 2-Napthylamine • Pentachlorophenol.
• Ethyl Methanesulfonate
Values reported for "non-detected" ("IT qualified) results will normally be standard analysis
reporting limit values for these compounds, which are near or greater than the delisting level.
For all compounds except Pentachlorophenol and bis(2-chlororethyl)ether. method 8270
methodology is not capable of achieving detection limits at or below the delisting levels
(method 8270 will likely detect Pentachlorophenol and bis(2-chloroethyl)ether at or just below
delisting levels if present). Evaluation of alternative analytical techniques found no methods
capable of reaching detection limits of 1/10th the delisting values for any of these compounds.
All of the alternative analytical techniques identified may be considered to be non-routine.
requiring special analysis equipment, extensive/specialized sample preparation, highly
specialized training/expertise, or a combination of all of these. These techniques are normally-
limited to highly specialized laboratories unlikely to possess suitable licenses allowing the
receipt of potentially radioactive samples. Implementation of any alternative technique at the
existing contracted laboratories would be cost prohibitive as the project would essentially need to
cover the entire cost (including equipment purchase, maintenance, and personnel [potentially
PHD level dedicated to the analysis]). Analysis by method 8270 is the best available
compromise at this time.
For a limited number of compounds measured by method 8270, routine non-detect reporting
limit values may not meet 1/10th of the delisting level, but will be below the delisting level. Such
compounds actually present in trace quantities will be detected below the delisting level.
nominally, to values below l/10lh of the delisting value. These compounds include the
following:
• Bis(2-chloroisopropyl)ether
• Hexachlorophene (this compound may not achieve MDL of 1/10th the delisting level).
31
-------
1.6.5 Polynuclear Aromatic Organic Analysis by Method 8310
The compounds measured by method 8310 are also analyzed by method 8270. In most cases, the
detection limits for method 8310 are lower than for method 8270. Final reporting of these
compounds will be the lower of the two values for any non-detect and the higher'of the two
values for any detected results. All routine reported non-detect values will be lower than 1 10!"
the delisting limits except for Dibenz[a.h]anthracene and Benzo(b)fluoramhene.
Routine reporting limits for Dibenz[a.h]anthracene will not meet the delisting level. If actualh
present in trace quantities. Dibenz[a.h]anthracene will be detected below thuTdelisting level.
nominally, to approximately l/5th of the delisting value. Evaluation of alternative analytical
techniques found no methods capable of reaching detection limits of 1/10 the delistins value
routinely.
Routine non-detect values for Benzo(b)fluoranthene may not meet 1/10th of the delisting level.
but will be below the delisting level. If actually present in trace quantities (as described" in the
above paragraph). Benzo(b)fluoranthene will be detected below the delisting level, nominally, to
values below 1/1 Olh of the delisting value.
1.6.6 Pesticide Analysis by Method 8081A
Routine reporting limits for Dieldrin will not meet l/10lh of the delisting level, but will be below
the delisting level. If actually present in trace quantities. Dieldrin will be detected, nominally, to
approximately 1/5' of the delisting value. Evaluation of alternative analytical techniques found
no methods capable of reaching detection limits of 1/10 the delisting value routinely.
For a limited number of compounds measured by method 8081. routine non-detect reporting
limit values may not meet l/10lh of the delisting level, but will be below the delisting ievel.^Such
compounds actually present in trace quantities will be detected below the delisting level.
nominally, to values below l/10th of the delisting value. These compounds include the
following:
• Aldrin
Alpha-BHC.
1.6.7 Bendiocarb Analysis
All analytical techniques identified for Bendiocarb may be considered to be non-routine.
requiring special analysis equipment, extensive/specialized sample preparation, highly
specialized training/expertise, or a combination of all of these. These techniques are normally
limited to highly specialized laboratories unlikely to possess suitable licenses allowing the
receipt of potentially radioactive samples. Implementation of any technique at the existing
contracted laboratories would be cost prohibitive as the project would essentially need to cover
the entire cost (including equipment purchase, maintenance, and personnel [potentially PHD
level dedicated to the analysis]).
32
-------
Analytical capability will continue to be monitored for all of the items discussed above. If
technical and economical methodology becomes available in the future, affected analysis will be
upgraded or be added to the requests for future samples.
1.6.8 Laboratory Quality Assurance and Control
For samples analyzed according to SW-846 procedures (EPA 1997). all of the QC requirements
outlined in EPA (1997) and in the applicable method will apply. At a minimum, the following
QC shall be performed:
• One method blank for every 20 samples, analytical batch, or sample delivery group
(whichever is most frequent) will be used to monitor contamination resulting from the
sample preparation process for each analytical method.
• One laboratory control sample or blank spike will be performed for every 20 samples.
analytical batch, or sample delivery group (whichever is most frequent) of samples for
each analytical method criteria to monitor the effectiveness of the sample preparation
process. The results from the analysis are used to assess laboratory performance.
• As appropriate to the method, a combination of either (1) a matrix spike and matrix spike
duplicate, or (2) a matrix spike and duplicate sample will be prepared and analyzed for
each 20 samples, analytical batch, or deliver)' group (whichever is most frequent). This
QC step will be performed on an ERDF leachate sample. The matrix spike results are a
measure of the accuracy of the analytes of interest that are measured in the sample
matrix. Laboratory- duplicates or matrix spike duplicates are used to assess precision and
will be analyzed at the same frequency as the matrix spikes.
1.6.9 Laboratory Quality Control Acceptance Criteria
The definitions of matrix spikes, matrix spike duplicates, and sample duplicates found in
Chapter 1 of SW-846 (EPA 1997) are used for this project. Matrix spikes will measure accuracy
via percent recovery, as defined in Chapter 1 of SW-846. Relative percent difference and
relative standard deviation, as defined in Chapter 1 of SW-846. will be used to assess precision.
The accuracy and precision limits that are listed in the SW-846 methods will be applied to the
results from the leachate for each sampling round. Analytes without accuracy and precision
limits in SW-846 will be assessed based on statistical evaluation of laboratory control sample
results using the same formulas presented for the compounds with limits. Because the leachate
will be aqueous with low probability of interferences, this is a reasonable approach.
1.7 DATA MANAGEMENT
1.7.1 Data Reporting
The laboratory must prepare a report summarizing the results of analysis, including associated
laboratory QC. Data summaries shall include, at a minimum, sample identity, sampling and
analysis dates, reduced data results, analytical detection limits for nondetect results, and a
33
-------
detailed case narrative for the following investigative and QC samples (as appropriate to the
method):
• ERDF samples
• All associated laboratory method blanks
• Associated batch matrix spike/surrogate recoveries
• Associated batch duplicate/matrix spike duplicate relative percent differences
• Associated batch laboratory control sample recoveries.
1.7.2 Data Validation
Level C data validation has been selected for leachate data per ERC procedures (WHC 1993a.
1993by This approach allows the review of all QC data, transcription error verification, and
holding time review. This level is the middle validation level and does not require review of raw
data and recalculation of data. The basic elements of this validation level include evaluation of
the following parameters (as appropriate to the method):
• Required analysis hold times
• Associated batch method blank results
" Associated batch matrix spike/surrogate recoveries
• Associated batch duplicate/matrix spike duplicate relative percent differences
• Associated batch laboratory control sample recoveries
• Reported analytical detection limits for nondetect results.
Should problems arise from the level C review, the project will perform recalculation and review
of raw data. Level C validation will be performed by qualified Sample Management personnel
or by a qualified subcontractor. Subcontract validation requirements will be defined in
procurement documentation or work orders, as appropriate.
1.7.3 Data Management
Data generated as a result of laboratory analysis will be managed and stored by the Sample
Management organization, as outlined in BHI-EE-01. Section 2.0, "Sample Management."
All validated reports and supporting analytical data packages shall be subject to final technical
review by qualified reviewers before their final submittal to regulatory agencies or inclusion in
reports or technical memoranda, at the direction of the ERDF STR. Electronic data access, when
appropriate, is through computerized databases (such as HEIS). Where electronic data are not
available, hard copies will be provided in accordance with Section 9.6 of the Hanford Federal
Facility Agreement and Consent Order (Tri-Party Agreement) (Ecology et al. 1996).
1.8 AUDITING AND ASSESSMENT
The ERC Quality Programs department may conduct random surveillance and assessments to
verify compliance with the requirements outlined in this SAP. the ERC Quality Management
Plan (BHI-QA-01. ERC Quality Program, Section 2.0). and the ERC procedures and regulatory
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requirements. Collectively, the surveillance and assessments will address quality-affecting
activities that include, but are not limited to. measurement system accuracy, field activities, data
collection, processing, validation, management, and QA programs.
Random surveillance and assessments will be structured to meet the following system and
performance audit classification. System audits consist of the evaluation of the measurement
system components to determine their proper selection and use. Performance audits ensure the
accuracy of the total system and its individual parts.
1.9 DATA QUALITY ASSESSMENT
Once the monitoring data have been verified and validated by a chemist, the results will be
evaluated by means of formal process and statistical tests that result in conclusions and
recommendations for the sampling and analysis of leachate. This evaluation is common!} called
a data quality assessment (DQA).
The DQA will be ongoing to coincide with the collection of monitoring data. In general. DQA
activities include the following:
1. Review project objectives and sampling design
2. Conduct a preliminary data review
3. Perform statistical analysis of the data
4. Draw conclusions from the data and make recommendations.
Project objectives will be reviewed when sufficient data have been generated to allow a
reevaluation of the project objectives to ensure they are still valid. The preliminary data review
includes reviewing the QA and QC reports, tabulating the data in different forms, and graphically
exploring the data. A preliminary data review can identify patterns, relationships, and potential
anomalies that may need to be further explored. Statistical analysis may include the examination
of time plots and performance of statistical tests to determine the significance of trends. Once
graphical and quantitative analyses are performed, the results will be interpreted and conclusions
and recommendations will be documented.
Moving average statistics may be used to determine compliance with delisting levels, in
accordance with the sampling design specified in Section 1.2. Until enough data are collected to
adequately identify cycles or trends, single concentrations will be used. Statistical estimates may
be used once adequate data are collected. Either a single concentration or a statistical value will
be compared with 10% of the delisting levels to determine whether an analyte should be
monitored on a routine or confirmatory basis. Each time new data are collected, the same DQA
procedure will take place to ensure ongoing compliance with delisting criteria.
Recommendations about the status of each analyte being monitored will be made on the same
schedule that data are being collected to ensure that the monitoring status of each analyte
remains up-to-date. Recommendations should be made in the context of the historical data and
with respect to the waste management processes being performed at the site. The addition of
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new or different waste streams and the management processes at the facility will be considered
each time that data are assessed.
Over time, enough data may be collected to perform more involved statistical analyses, such as
trend analysis, control chart analysis, time series modeling, and correlation analyses between
analytes. These analyses may provide better estimates of uncertainty than a moving standard
deviation, and their use should be considered for incorporation into the overall data assessment
program.
2.0 REFERENCES
49 CFR 171-177. "Department of Transportation Hazardous Materials Requirements." Code of
Federal Regulations, as amended.
BHI-EE-01. Environmental Investigations Procedures. Bechtel Hanford. Inc., Richland.
Washington.
EIP 1.5. "Field Logbooks"
EIP 2.0. "Sample Event Coordination"
EIP 3.0. "Chain of Custody"
EIP 3.1. "Sample Packaging and Shipment"
BHI-QA-01. ERC Quality Program, Bechtel Hanford, Inc.. Richland, Washington.
BHI-QA-03. ERC Quality Assurance Program Plans. Bechtel Hanford, Inc., Richland.
Washington.
Procedure 5.1. "Field Sampling Quality Assurance Program Plan"
DOE-RL, 1997, Proposed Plan for an Amendment to the Environmental Restoration Disposal
Facility Record of Decision, DOE/RL-97-60. Rev. 0, U.S. Department of Energy.
Richland Operations Office, Richland, Washington.
DOE-RL. 1998. Environmental Restoration Disposal Facility Leachate Delisting Petition.
DOE/RL-98-47. Draft B, U.S. Department of Energy, Richland Operations Office.
Richland. Washington.
EPA. I995a. Chemical Analysis of Water and Wastes. EPA-600/4-79-020, U.S. Environmental
Protection Agency. Washington. D.C.
EPA. 1995b, ERDF Record of Decision, U.S. Environmental Protection Agency, Washington.
D.C.
EPA. 1997. Test Methods for Evaluating Solid Waste, Physical/Chemical Methods. SW-846.
3rd Edition, as amended by Updates I (July. 1992). IIA (August. 1993). IIB (January.
1995), and III. U.S. Environmental Protection Agency. Washington. D.C.
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EPA, Ecology, and DOE, 1996, U.S. Department of Energy Environmental Restoration Disposal
Facility - Hanford Site Benton County, Washington - Explanation of Significant
Difference, U.S. Environmental Protection Agency. Washington State Department of
Ecology, and U.S. Department of Energy. Olympia, Washington.
FDNW, 1998, Hanford Site Liquid Waste Acceptance Criteria. HNF-3172. Fluor Daniel
Northwest, Inc., Richland, Washington.
WHC. 1993a, Data Validation Procedures for Radiological Analyses. WHC-SD-ED-SPP-001.
Rev. 2. Westinghouse Hanford Company, Richland, Washington.
WHC, 1993b, Data Validation Procedures for Chemical Analysis. WHC-SD-ED-SPP-002.
Rev. 2, Westinghouse Hanford Company, Richland, Washington.
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