Free Statement of Facts - District Court of Federal Claims - federal

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Exhibit 26-D

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Section 8.0 Quality Assurance

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QUALITY ASSURANCE Filed 07/27/2006 Page 3 of 36 August 1989

8.0 - QUALITY ASSURANCE SCOPE OF AUDIT 1. 2. 3. 4. 5, 6. 7. 8. 9. Determine the Quality Assurance if (QA) program place conforms the in to applicable DOE Qrdere. Determine laboratory practices conformto documented programs. if QA Review samplehandling and an~Jysissequence the laboratories. the in Determine QArequirements offsite laboratories andif the laboratories satisfy the for these requirements. Determine the activities in the laboratories conform Good if to Laboratory Practices. Coordinate with waterspecialists to evaluatethe f~etd sampling quality assurance/ quality control practices. Evaluatelaboratory quality control measurements. Reviewlaboratory data management systems, Evaluatethe organizational structure of the laboratory QAprogram.

QUALITY

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ASSURANC~ August 1989

QUALITY ASSURANCE FINDINGS

QNAF-1 QA/AF-2

Laboratory Qualit~ Assurance Program/Practices Building 881 - GeneralLaboratory Laboratory Quality Assurance Program/P~ctices Building 123 - HS&E Laboratory

BEST MANAGEMENTPRACTICES: QNBMP-1 QNBMpo2 Data Management Systemfor Environmental Monitoring QNQCData Provisions for Transmission Updated of Laboratory Procedures

NOTEWORTHY PRACTICES: QA/NP-1 ProgressionTraining for LaboratoryTechnicians

¯ 8-3

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QA, AF-I

Audlt

Ft~lna

Number Laboratory Quality Assurance Program/Practices BuilDing 881 GeneralLaboratory

Audit ptn~lno Tltle

Audlt Findtna ~lr~d AooHcable Reference Theprograms practices associatedwith the quality assurance quality control and and the environmentalanalyses conductedat the Building 881 General Laboratory are not adequateto document validity of the analytical data. Valid data are necessaryto the provide a defensible basis for remedial actions and assessmentsof environmental impacts.Deficiencies notedduring the audit include:

1)

Thereis no single document that describesin detail the program,organization, procedures,and responsibilities associated with the quality assurance/quality control for environmental monitoring analyses. The Building 881 General Laboratory is in the Quality Laboratories Division, which also includes the Plutonium Operations Support Laboratory, the Production Support Laboratory, and the ChemicalStandardsLaboratory. The quality assuranceprogramfor the Quality Laboratories is presented in ~ Assurance Pr__qLg_~, Quality Laboratories, July 1988. Dueto the wide spectrum activities that this quality of assurance document covers, there is a lack of information specific to the quality assurance program place at the Building 881 GeneralLaboratory. in The Quality Assurance/Quality Control Coordinator (QA/QCC) the General for Laboratory reports directly to the Manager the GeneralLaboratory and does of not have the organizational freedom to report quality problems to upper management independently pursue corrective actions. The QA,organization, and as it is currently set up, presents the potential for conflict between quality assurance needsand production needsin the GeneralLaboratory. This potential conflict also exists for the LeadChemists are responsiblefor the monitoring who of quality control work performed in their respective areas and are also responsible the timely productionof analytical data. When situation arises for the that data is to be transmitted to the c~ient but adequate quality control hasnot beenperformed,the decision to provide the data or completethe quality control rests with the AreaChemist (I-QA-4). Theposition of Quality Assurance Officer, with overall responsibility solely for the maintenance quality assurance/quality of control programs all laboratories in for the Quality LaboratoriesDivision, doesnot exist. As a result, the environmental monitoringquality assurance/qualitycontrol program the Quality Laboratories for is fragmented, with responalbilities for various aspectsof the program delegated to personnel whodo not directly report to the same management level and are not organizationallylinked. Environmental monitoring analysesare performedat RockyFlats Plant (RFP) two laboratory groups, Building 881 GeneralLaboratoryand Building 123 Health, Safety, and Environment (HS&E) Laboratory. The Building 881 General Laboratory is responsible for the analysis of volatile organics, semi-volatile organics, PCBs, HSLmetals, water quality parameters, and radiochemical
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2)

3)

4)

Case 1:91-cv-01362-CFL QA/AF-1
August 1989

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parametersfor groundwatersamples,selec:ed surface water samples,and waste characterization samples. The twolaboratories do not coordinate with one another to maintain consistencybetween their respective proceduresand quality assurance programs. Laboratory audits or "Self Evaluations" of the Building ~81 GeneralLaboratory are performed by the Oivision Quality AssuranceCoordinator (QAC)for the Quality Laboratories Oivision, and laboratory personnelwhoin somecaseshave not taken an in-houseauditing training courseentitled "Basic Quality Assurance Auditing" (I-QA-13). The Self Evaluation report, "Evaluation of the Chain-ofCustody Recordsand the SampleStorage Pa'ameters of GroundwaterSamples" (March28, 1989)wasreviewed. This report did not include documentation the of close-out or post audit meetingthat is required to be conducted the Quality by LaboratoriesDivision audit procedure L-1005.Thereis no formal tracking system for following findings throughcorrective actionsandclose-out.

6)

Thereport of an audit of the Building 881 GeneralLaboratory and the Building 123 HS&E Laboratory performed by the RockyFiats Area Office (RFAO)Safety and Environmental Evaluations Branchin October1988stated that "the current auditing system does not provide adequateevaluation of overall laboratory performance"and recommended "NE]Caudit protocols should be used as a that basis for developingan audit systemthat frequently evaluatesthe laboratories entire QCprogram'. Thelaboratory refrigerator in which volatile organic analysis (VOA) samples are stored did not have holding blanks, eventhough there wereVOA samplesstored there for future analysis. Theanalysis of holding blanks is required by the EPA Contract Laboratory Program(CLP) Statement of Work (SOW) dated February 1988. The blind reference samples(IMECS samples) submitted for analysis are not packaged laboratory sample in bottles and, therefore, the analyst is awarethat the samplesare reference samples. This maylead to lhe samplesbeing given special care. , There are no formal data review procedures for the Building 881 General Laboratory. Environmental monitoring data and associated quality assurance/quality control (QA/QC) data producedat the Building 881 General Laboratory are reviewedby the Lead Chemist for the particular analysis and a decision is made concerningthe acceptabilib/of the data (I-QA-1). Thechemists review the data to determineif appropriate QA/QC requirements,such as blanks, duplicates, and blind reference sampleanalysis, have been met. The Quality Control Coordinatorthen reviews the data for consistencyand completeness (i-QA-2). Environmental monitoring samples awaiting analysis are stored in refrigerators located inside the laboratory andin the adjacent hallway. These refrigerators do not havelocks. Thetemperature the refrigerators is currently monitored in during normal work days but not on weekends. WorkOrder has beensubmitted for the A placementof Iockable hasps on the refrigerators and for incorporation of automatictemperature loggerson the refrigerators (I-QA-1).

7)

8)

9)

11)

Volatile organic standards are kept in a refrigerator in the GC/MS whichis room located approximately 5-6 feet from the GC/MS up to do VOAs.Standard set
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laboratory practice is to keepstandardsstored in areas away from the analytical instrumentsin order to avoid potential contamination samples to proximity of due of standards. Onerefrigerator (#137-1R) being used for the storage of VOA samples was obsewed have a temperature(7 degreesC) in excessof that required by EPA to procedures(4 degreesC), and one refrigerator (#266-5R)was observedto no temperaturemonitors. 13) Standardsa~d VOA samplesare being stored in the same refrigerator (#137-1R), This increasesthe potential for cross-contamination. The analytical laboratory proceduresfor the Building 881 General Laboratory haverecently, within the last Meyears, beenrevised. A review of the procedures by the audit teamrevealedthat certain laboratory activities are not coveredby written procedures or procedures formally issued through the Quality Laboratories Division. Laboratory activities not coveredby formal procedures include, but are not limited to, the following: ¯ ¯ Data review and approval Glasswarecleaning and preparation Preparationandretention of organicanalytical standards Analysisof volatile organics andsemi-volatile organicsby CLP methods Analysis of Hazardous SubstancesUst (NSL) metals by ICP and Preparation retention of inorganic analytical standards. and 15) SeeAudit Finding RAD/AF-5 a related radiochemistry-specificfinding. for and Requirements

A##llcabl e Cltetton

Interim Guidelines~ndSoecifications for ~=reoarfng Quality Assurance Plans: EP A-QAMS-O05/80. Guidelinesfor Soecifications for PreoarfngQuality Assurance Pronram Plans: EPA-QAMS-004/80. Strategy for the Imolementationof the EF~A'sMandatoryOuelltv AssuranceProaram: EPA-QAMS-001/80. DOE Order 5700.6B, ~.

40 CFR 136.2, Guidelinesestablishin~ test oroced~res th~ apalvsis of oollutants. for "Clarification of Applicable Radiation Protection Standardsfor the public and the Environment,"Memorandum Distribution for John Tseng, Acting Director, Office of to Environmental Guidance and Compliance, U.S. Department of Energy, November 4, 1987. "Radiation Standardsfor Protection of the Public in the Vicinity of DOE Facilities," Memorandum Distribution from W. A. Vaughan,Assistant Secretary, Environment, to Safety, and Health, U.S. Department Energy,August5, 1985. of

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QA/AF-I

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DOE Order 5484.1, Chapter3 (Draft) A formal comprehensive laboratory quality assuranceprogramis necessaryto ensure and document that analytical data are accurate, ~recise and defensible. Theneed for such programsis explained and guidance for their development provided in numerous documents, including: Establishing a Quality Assurance Program Analytical ChemistryLaboratories Ior within the Nuclear [ndust~, ASTM C1(309-83. Manual the Certification of LaboratoriesAnalyzingDrinking Water, EPA-570/9for 82-002. October, 1982. Handbook for Analytical Quality Control in Radioanalytical Laboratories, L.Kanipe, U.S. Environmental Prote~on Agency,1977,EPA-600/7-77-088. Evaluation of Internal Control Measurements Radioassay, in HeaJthPhysics, A. S. Goldin, September 1984, Pages361-374. Principles of Quality Assurance Chemical of Measurements. Taylor National J.K. Bureauof Standards. NBSIR-85/3105, February 1985. Nendbook Analytical Quality Control in Waterand W~stewater for L~boretories: EPAJ600106. Samolin{3end ChemicalAnalysis Quality Assurance Programof U.S. ArmyToxic ~pd Nazerdous Materiels Aoencv.April 1982. Department the Army, U.S. Army of Toxic and HazardousMatsda~sAgency, AberdeenProving Ground, MD21010. Re¢ommendatlon~ 1) Develop a comprehensive quality assurance program, manual and implementation procedures following the guidance of ASTM C1009, and Interim Guidelines and Specifications for Preparing Quality AssuranceProject Plans (QAMS-005/08),U.S. EPA. Assignresponsibility for monitoring and directing the quality assurance program in the laboratory to the QA/QCC not the LeadChemists.This wouldminimize and the potential for bypassing quality assurancerequirements in order to meet production schedules. Establish an organizationalstnJcture suchthat QA/QC personnel report directly to a Oivision Quality Assurance Officer. Theposition of Quality Assurance Officer should be established to ensure that quality concernsfrom the laboratories are investigated at upper management levels. TheQuality Assurance Officer should report directly to the Manager Quality Laboratories. This organization would of provide organizational independence from production concerns. The Building 881 General Labioratory and the Building 123 HS&E Laboratory should coordinate in an effort to develop consistent laboratory proceduresand quality assuranceprograms.Thereport of an audit of the Building 881 General Laboratory and Building 123 HS&E Laboratory performedby the RockyFlats Area Office (RFAO)Safety and Environmental Evaluations Branch in October 1988 recommended that "Rockwell should develop a QA/QCManual designed to
8-8

2)

3)

4)

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QA/AF-I

accommodate satisfy uniform environmentalprogramprotocols to be followed and by both the 881 QLand 123 HS&E Labs, or any other onsite labs involved in the environmental program." Ensure that all Laboratory personnel who perform audits for the Quality Laboratories Division are trained in auditing techniquesand the Division audit procedure(L-1005).

6)

Performinternal audits of procedure(L-1005) and associated documentation ensure that the Self Evaluations are performedaccording to the procedureand that the reports accuratelyreflect Self Evaluation activities. Revise procedure L-1005 to require documentation in the audit report of all procedural requirementsthat havebeen performed. Revise audit procedureL-1005to include a formal systemby which findings can be accurately trackedthroughcorrective action andclosure.

s) g)

Prepareholding blanks for VOA analysis and store them in the samplestorage refrigerator with environmental monitoringsamples. Revise proceduresfor the submissionof reference standards (IMECS samples) so that the analyst cannotreadily identify themas performance checks. Develop formal procedurethat details the responsibilities and methods be a to employed the review of environmentalmonitoring data. Theprocedureshould for include provisions for documentation of data reviews by appropriate QA/QC personnel. Continuously monitor all refrigerators used for the storage of samplesand standards. A written procedureshould be issued that details the temperature monitoring methodand proceduresto follow whena refrigerator fails or the temperature dses abovea set point.

12)
13)

Donot store standards samples the same end in refrigerator to avoid the potential for cross-contamination. Donot locate standardsrefrigerator/freezers in the same roomas the analytical instrument employing those standards to minimize the potential for crosscontamination and elevated backgrounds, Conducta thorough review of laboratory activities proceduresthat mustbe developed. to identify additional

14) lS)

See Audit Finding RAD/AF-5 a related rediochemistry-specific finding and for recommendations.

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Quality Assurance Q~AF-2

QA/AF-2 Page 10 of 36 August 1989

Audit ~=~ndlnaTitle

Lal3oratory Quality Assurance Program/Practices Building 123 HS&E Laboratory

Audit Flndlnct

and Aoollcable

Theprograms practices associatedwith the quality assurance quality control for and and the environmental analyses conductedat the Building 123 HS&E Laboratory are not adequateto document validity of the analytical data. Valid data are necessaryto the provide a defensible basis for remedial actions and assessments environmental of impacts.Deficienciesnoted during the audit include: 1) 2) Thelaboratory doesnot havea clearly defined comprehensive quality assurance program.Thereis no up-to-date quality assurance manual. The Quality Control Coordinator (QCC)for the Building 123 HS&B Laboratory reports directly to the Laboratory Manager for the Building 123 Lab and has minimal contact with other QA/QC personnel for HS&E (I-QA-7). The QCC does not have the organizational freedom to report quality problems to upper management independently pursue corrective actions. The QAorganization, and as it ,is currently set up, presents the potential for conflict between quality assuranceneedsand production needsin the HS&E Laboratory. This potential conflict also exists for the LeadChemists are responsiblefor the monitoring who of quality control work performed in their respective areas and are also responsible the timely production analytical data. for of TheHS&E Quality Assurance Coordinator (QAC)does not have responsibility for program oversight of quality activities with respect to environmental monitoring analysesfrom the Building 123 HS&E =Lab. Environmental monitoring analyses are performedat RockyFlats Plant (RFP) two laboratory groups, Building 881 GeneralLaboratoryand Building 123 Health, Safety, and Environment(HS&E) Laboratory. The HS&E Laboratory is responsible for radiochemical analyses surfacewater, effluent air, ambient of air, soils, end vegetation; and the analysis of air samples for beryllium. The two laboratories do not coordinate with one another to maintain consistencybetween their respective procedures quality assurance and programs. Thereport of an audit of the Building 881 GeneralLaboratoryand the Building 123 HS&E Laboratory performedby the F~ockyPlats Area Office (RFAO) Safety and Environmental Evaluations Branchin October1988~stated that "the current auditing systemdoes not provide adequateevaluation of overall laboratory performance"and recommended "NE!Caudit protocols should be usedas a that basis for developingan audit systemthat frequently evaluatesthe laboratories entire QCprogram". Duplicateanalyses are not conducted all analytical procedures for (I-QA-8).

3)

4)

5)

6)

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7) 8) 9)
10)

Blankfilters (method blanks) for beryllium(Be) analysisare not regularly included in analytical batches (I-QA-7). Reagent blanksfor Be analysis are analyt.Bd aRerapproximately every forty-llve samples (I-QA-7). Daily instrument calibration data for the analysis of Be is not reviewedby the Lead Chemistor QCC (I-QA-21). The instrument service log for the atomic absorption spectrophotometer employed beryllium (Be) analysis wasnot complete. Information concerning for the preparation of standardsin February1989and installation of a newBe lamp in May 1989wasnot ~ncluded the log. in There are no formal data review procedures for the Building 123 HS&E Laboratory. Environmentalmonitoring data and associated quality assurance/ quality control (QA/QC) data producedat the Building 123 HS&E Laboratory are reviewedby the LeadChemistfor the pEticular analysis and a decision is made concerning acceptability of the data (I-QA-8). Thechemists the reviewthe data determineif appropriate QA/QC requirements, such as blanks, duplicates, and blind reference sampleanalyses, have been met. The data is not reviewed at any level abovethe Lead Chemist. The analytical laboratory proceduresfor the Building 123 HS&E laboratory are currently undergoing revision and incorporation into a procedure control system. The revisions werebegunapproximatelyeight monthsago and completionis not plannedfor another six months (I-QA-11). A reviewof revised procedures the audit teamrevealedthat the format for the by proceduresdoes not include a separate section for quality assurance/quality control (QA/QC). QA,'QC The information is included in various sections of the procedure is not identified as QA/QC but related.

11)

12)

13)

Refer to the Audit FindingRAD/AF-3 a related radiochemistry-specific for finding. Clta~lon and Requlremen~

Agpllgable

Int~rfr n GuidelinesandSoecificatfonefor PreDating Quality Assurance Plans: EPA-QAMS-005/80. G~4idelines for Soecificafions for PreoadnQ Quality Assurance Program Plans: EPA-QAMS-004/80. Stratedv for the lmolementation of the EPA'e MandatoryQualib/ AssuranceProgram: EPA-QAMS-001/80. DOE Order 5700.6B, Quality Assurance. 40 CFR 136.2, Guidelinesestabtishinotest orocedures the analysisof oollutants. for "Clarification of Applicable Radiation Protection Standardsfor the public and the Environment,"Memorandum Distribution for JohnTseng, Acting Director, Office of to Environmental Guidance and Compliance, U.S. Department of Energy, November 1987. 8-12

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"Radiation Standardsfor Protection of the Public in the Vicinity of ODE Facilities," Memorandum Distribution from W. A. Vaughan,Assistant Secretary, Environment, to Safety, anc:~ Health, U.S. Department Energy,August 198& of 5, DOE Order 5484.1, Chapter3 (Draft) A formal comprehensive laboratory quality assuranceprogramis necessaryto ensure and document that analytical data are accurate, precise and defensible. The needfor such programsis explained and guidance for their development provided in numerous documents, inctuding: Establishing a Quality Assurance Program Analytical ChemistryLaboratories for within the Nuclear Industry, ASTM C1009-83. Manual the Certification of LaboratoriesAnalyzingDrinking Water,EPA-57C)/9for 82-002, October, 1982. Handbook for Analytical Quality Control in Radioanalytical Laboratories, L.Kanipe, U.S. EnvironmentalProtection Agency,1977,EPA-600/7-77-£)88. Evaluation of Internal Control Measurements Radioassay, in Health Physics, A. S. Goldin. September1984, Pages361-374. Prfncip~es of Quality Assurance Chemical of Measurements, Taylor J.K. National Bureauof Standards, NBSIR-85/3105, February 1985. Handbook AnalYtical Duality Control in Waterand Wastewater for Laboratories: EPA/600106. SOl'holing and ChemicalAnalysis Quality AssurancePmaram U.S. ArmyToxic of and ;.4azardousMaterials Agency,April 1982. Department the Army,U.S, Army of Toxic and HazardousMaterials Agency, AberdeenProving Ground, MD21010. Reqqmmenda~lons

1) 2)

Developa comprehensive quality assuranceprogramand manualfollowing the guidance of ASTM C1009. The Quality Control Coordinator (QCC)for the Building 123 HS&E Laboratory should have organizational independence from production concernsin order to properly implement maintain an effective quality assurance~qualitycontrol and program, The QCC should report directly to the Division Quality Assurance Coordinator for HS&E. The Division Quality AssuranceCoordinator should overseethe implementation and maintenance the quality assurance/quality of control program the Building for 123 HS&E Laboratory. The Building 881 General Laboratory and the Building 123 HS&E Laboratory should coordinate in an effort to develop consistent laboratory proceduresand quality assuranceprograms.Thereport of an audit of the Building 881 General Laboratory and Building 123 HS&E Laboratory performedby the RockyFlats Area Office (RFAO)Safety and Environmental Evaluations Branch in October 1988 8-13

3)

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recommended that "Rockwell should develop a QAIQC Manual designed to accommodate satisfy uniform environmentalprogramprotocols to be followed and by both the 881 QLand 123 HS&E Labs, or any other on-site labs involved in the environmental program," Revise audit proceduresto include a formal systemby which findings can be accuratelytrackedthroughcorrective action andclosure. Incorporate Environmental Management personnel into the laboratory audit process since these are the ultimate usersof the data. 7) Initiate the anatysisof duplicatesamples all analytical procedures. for Increasethe frequencyof analysesof beryllium method reagent blanks to 10 and percent of sampleanalyses,

9)
10)

Initiate review of daily calibration data for the beryllium analysis by the Lead Chemist or QCC. Prepareand implement formal procedures the use of instrumentservice logs. for Develop formal procedur~that details the responsibilities and methods be a to employed the review of environmentalmonitoring data. Theprocedureshould for include provisions for documentationof data reviews by appropriate QA/QC personnel.

12) 13)

Expedite the revision of analytical laboratory procedures.Include a separate section for QA/QC the procedure in format. SeeAudit Finding RAD/AF-3 a related radiochemistry-specific finding and for recommendations.

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Assurance QNBMF-I

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I~M l=lndln~ Title P

Data Management Systemfor Environmental Monitoring QAJQC Data

The data management systemfor environmental monitoring quality assurance/quality control (QA/QC)data requires manualentry and review and is therefore subject human error. Theuse of inaccurate QA/QC data maylead to erroneousinterpretation of dataquality andsuitability. The management environmental monitoring QA/CC of data in the Building 881 General laboratory (QA-1, 2) is performed manually. The installation of "Lab-SAM"data management systemis in progress. However,additional funding is neededto upgrade the system to manage the QA/QC data required by the RCRA ProgramOffice. QA/QC data is checked by the Lead Chemists and for someparameters, such as volatile organics and radionuclides, it is entered into software programs which producecontrol charts. Theproduction the control charts for volatile organicsis done the endof the of at quarter(I-QA-22),whichnullifies the effectivenessof control charts as tools for immediate evaluation of analytical performance. Control charts are intendedto provide information on trends associated with QA/QC data. By plotting at the end of the quarter, problems that developearly in the quarter are not recognized correctedin a timely manner. and The data management system used in the Building 123 HS&E Laboratory is the "Flow Gemini"system.This data management systemis not specifically for laboratory data and consequentlyc~nnot readily process QA/QC data such as duplicates (I-QA-7). Requests have been submitted for funding to changethe data management systembut no action has beentaken to date (I-QA-6). A~lh;:able BMP and Recommendations

1)

The data managementsystem, "Lab-SAM," for the Building 881 General Laboratory needs to be brought on-line as soon as possible and upgradedto handle the data required by the RCRA ProgramOffice. Incorporation of this systeminto the data flow will decreasedata turnaround time and increase the ability of the laboratory to properly manage interpret QAJQC and data. Control charts should be updatedandrevieweddaily in order to determineif any out-of-control conditions are developingand permit immediate corrective actions to be taken. Thedata management system, "Flow Gemini," in operation in the Building 123 HS&B Laboratory needsto be upgraded order to handle simple QA/QC in data such as duplicates. Duplicate analysesprovide information on data precision and samplepreparation techniques.

2) 3)

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Quality Assurance QA/BMP-2

QA/BMP-2 PageAugust1989 15 of 36

~MPFtndlno Title BMP Flnc~|.Do and Acollceble

Provision for Transmission Updated of Laboratory Procedures

Thereis no formal procedure the timely transmissionof revised or updated for laboratory procedures from the Building 881 GeneralLaboratory to the FICRA Program Office (I-QA-13)oReferring to outdatedprocedures personnelinvolved in the interpretation by of data mayresult in incorrect conclusions related to accuracyand precision and the significance of the result. If modifiedprocedures not providedby the laboratory, the ar~ only method avallal~le to the RCRA Program Office for identifying a proceduralrevision is throughthe annuallaJboratoryaudit. Aoallcable BMP and Recommendations

Develop formal protocol fer the timely transmissionof revised or updatedlaboratory a procedures from Building 881 General Laboratory to the RCRA ProgramOffice. One effective wayto accomplish this is to include the RCRA Office as a part of the formal sign-off sequence proceduralrevisions. for

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QuaJity Assurance QAJNP-1

Page 16 of 36

August 1989

Audit Ftndlnc~ Title Noteworthy Practice

Progression Training for L~boratory Technicians

The Progression Training Programfor laboratory technicians in the HS&E Laboratory providesextensivetraining in various aspectsof laboratory activities. This program goes beyondthe procedure-directedtraining that is typically found in laboratories. This program strengthens the overall backgroundof the technicians and should aid in improving performance. The ProgressionTraining Program was implemented is currently maintainedby and Progression Programsubcommittee. The programis defined by a document entitled "Progression Programs, RockwellInternational - Rocky Flats Plant, October1, 1989." TheProgressionProgram comprised training modules is of designed first provide the to technician with general science training and progressing up to detailed "hands on" experience specific laboratory activities. Thetechnicians are tested during andafter in the modulesand all grades are permanentlydocumented. Technicians whoare falling behindin the training or not satisfactorily completingthe modules counseledand are tutored. Thetraining program lasts three to four years, depending the technician's on assignedOivision. Successful completion of the Progression Training Programenables the employeeto receive top pay within the employment category and provides the technician with intensive training in vadous aspectsof chemicaJ sciencesandlaboratory activities. This program should be modified and expanded to include other personnel with responsibilities for collecting environmental samples conductinglaboratory analyses. or The programmight be improvedby adopting objective-based training methodology such as that supportedby the Institute for Nuclear Power Operations.TheRockyFlats Plant (RFP)should also investigate the possibility of obtaining college credit for program participants.

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inactive

Waste Sites F~e~eases

and

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INACTIVEWASTE SITES & RELE-~$ES Augu~tt 1989 Page 18 of 36

9,0 - INACTIVE WASTESITES AND RELEASES SCOPE OF AUDIT Adherenceto schedule and technical content of 1986 ComplianceAgreement regardinginactive wastesite issues a. b.
o

SWMUs be closed under intedmstatus (inactive sites to closure/post-closure SWMUs be remediated under CERCLA/RCRA to (high. medium, and low pdodtysites)

Excessproperties per SARA 120(h) a. b. Existenceof these properties Conformance with reporting procedures

Spill reporting andnotification procedures a. b. Review relevant procedures all Determineconformancewith CERCLA Section 103(a)

Conformance with National Contingency Plan (based on 1986 Compliance Agreement) a. b. c. d. Preliminary Assessments/Site Investigations (PA/SIs) and CEARP PhaseI Report Development Remedial of Investigation/Feasibility Study(RI/FS) work plans Development RI/FS reports of ¯

Adherence response of action activities to guidance

Compliance with SARA Title 111 a. b. Section302notification Section 304, 311,312,and 313 reporting

c. Methodsused to develop 311 through 313 reporting Closure/Post-Closure Plan conformance with RCRA CFR (40 265 Subpart G) Present landfill inspection a. Conformancewith RCRA (40 CFR257) b. Management asbestos disposal of

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~= IHACTIV WASTE SITES& RELF-~,SES August1989 Page 19 of 36

INACTIVE WASTESITES AND RELEASES FINDINGS AUDIT FINDINGS: IWS/AF-1 IWS/AF-2 IWS/AF-3 IWS/AF-4 IWS/AF-5 IWSIAF-6 I~EST Lack of a Finalized and Implemented Community Relations Plan for the Rocky Fiats Remedial Corrective Action Program IncorrectEntries in SARA, Title III, Section313Reports (EPA Form R) Lackof an AdministrativeRecord the Environmental for Restoration Program Inadequate Remedial Investigation/Feasibility Study Work Plan - LowFdodtySites (::)mission of SWMUs the Environmental from Restoration Program Inadequate Remedial Investigation~Feasibility Study- 881Hillside

MANAGEMENT PRACTICES: Lackof a Unified Spill Reporting Notification Procedure and InadequateTimefor Preparation and ReviewCycle for EnvironmentalRestoration Documents Determination Threshold of Amounts SARA for Title II1, Section 313 Reporting Repriodtization the Odginat of Landfill

IWS/BMP-1 IWS/EMP-2 IWS/I~MP-3 IWS/BMP-4

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IW$;AF-1 ~,ugust 198~

Inactive WasteSites and Releases IWS/AF-1 Lack of a Finalized and Implemented Community Relations Plan for the RockyFlats Remedial/Corrective Action Program

Audit Ftndlna Numbe~ Audit Pindlna Title

The RockyFiats Plant (RFP) has not finalized or implemented Community a Relations Plan for its Remedial/Corrective Action Program. A draft plan was prepared by RFP (IWS-42)and submitted to the U.S. EPA,RegionVIII, in August, 1986. Comments were providedby EPA,althoughit is not documented whatdate or in whatform (written or on verbal) (I-IWS-10, I-IWS-17, I-IWS-18, 1-1WS-22, I-IWS-28). A meetingwasheld and eady 1988 with EPAin which comments Ihe Community on Relations Plan and the need to finalize the plan were discussed. A final plan has not yet been produce~ or implementedby RFP. A~t~llcabte Citation and Requirements

Section 10.f(1) of the Compliance Agreement Order of Consentbetween and DOE.EPA, and ColoradoDepartment Health (CDN) of (effective July 31, 1986) requires that within 30 daysof the effective date of the agreement, shall submit to EPA COH draft DOE and a communications strategy/community relations plan. In addition, a final strategy/plan shall be preparedwithin 14, days of receipt of EPA/CDH comments. Recommendations TheRFP Community Relations Plan for the remedial/corrective action program should be finalized and implemented. Guidance provided in the Office of Solid Waste and Emergency Response (OSWER) Directive 9230.0-3B, Community Relations Superfund: A Handbook published by EPAin June 1988, should be followed. Before initiating work on this document, RFPshould meet with EPAand CDHcommunity relations specialists to solicit their advice and input. Comments meetingsand from reviews should be documented writing and agreedto by all principals. Thereshould in be completecoordination between groups involved in environmentalrestoration and all community relations. Important features of a communityrelations plan that should be incorporated are interviews with the public to allow their participation in development the plan, of establishment of an information repository, and a strategy for public informational meetings, releases, and newsletters. Oncedeveloped, the Community Relations Plan should be implemented.

IW$1AF*2

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Inactive Waste Sites and Releases IWS/AF-2 IncorrectEntriesin SARA I11, ~tle Section 313, Reports (EFAForm

~gdlt Flndlnt~ Title Audlt Ftndtnd and Aoollcable

Information has beenincorrectly calculated and entered on EPA FormR, Toxic Chemical Release inventory Form.For example,for carbontetrachloride, 1,1,1-trichloroethane, and Freon 113 for reporting years 1987 and 1988 (IWS-30, and 1WS-31) the entry FormR indicates the estimate is basedon monitoring data or emissionsmeasurements. In actuality, the estimatesfor quantities discharged liquid effluent streams based in are on process knowledge and engineering judgement. FormR indicates the methodsused for estimating the amounts carbontetrachloride, for reporting years 1987and 1988 of andfor 1,1,1 -thchloroethane,in 1988, releasedto stacks or air point sourcesare based on massbalance calculations. The estimates are actually basedon best engineering judgement. (IWS-32,I-tWS-20, and 1-]WS-33).In addition, the basis of the estimate for stack or point air emissions Freon113in the 1988reporting year is missing. for Calculationsof 1987carbontetrachtoride air andliquid influent concentrations waste to treatment systems,containedwithin the documentation file, are in error, resulting in higher values being reported in Form (I-lWS-39). R

Section 313 of SARA/CERCLA "lqtie 111 (Emergency Planning and Community Right-toKnow) requiresthat the owner operatorof a facility subject to the requirements that or of Section complete Form R. The owners and operators of the Rocky Flats Plant are subject to these requirements. Re¢0mmendatlon~

1)

Initiate a programfor the formal review of calculations and the transfer of information from calculation sheets, memos, other documentationused in or preparing release estimates. The completedforms should also be reviewedfor accuracyand completeness,as part of a formalized quality assurance/quality control program,by senior staff or technical personnelwithin the groups that generate the technical work, such as the WasteOperations and Environmental Management Groups.

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tWS/AF*3 August 1989

Inactive WasteSites and Releases IWS/AF-3

,~gdlt Flndlno Title Audit Flndln~ and Aootlcable ReferencEs

Lack of an Administrative Record for the EnvironmentalRestoration Program

The Rocky Flats Plant (RFP) does not have administrative records documentingthe information usedto make decisions on the selec~onof responseactions under CERCLA. Thesite is presently performingor planning response actions at several sites, including the 881 Hillside; the 903 Pad, Mound,and East Trenches; and the LowPriodty Sites. Thestudies beingperformed thesesites have, andwill, result in information needed at to formulate remedial actions. Information generated to date has not been placed in administrativerecords. Aoollcable Citation and Requirements

Section 113(k) of CERCLA requires the establishment of administrative records for selection of CERCLA response actions. Administrative records consist of documents that are to be considered[n selecting a responseaction and those which demonstratethe public's opportunity to participate in the selection of the action, ExecutiveOrder12580 authorizesFederalagenciesto establish administrative recordsfor selection of response actions for facilities under their control; these agenciesmustcompile and maintain recordsas required by regulations. Reqommendal;lons RFPshould establish administrative records for information developed during response/remedial action activities. As part of this effort, a programfor community involvement should be developed. See related Finding IWS/AF-1.The records should be available to the public at, or near, the plant. RFPhad contacted the City of Westminsterregarding the establishment of a public document room in a municipal building (I-IWS-22). RFPhas, however,morerecently decided to establish a room Building 60, a public access facility nearthe westgate (I-IWS-47). Guidanceon the development maintenance administrative records is available and of from the U.S. EPAOffice of Solid Wasteand Emergency Response.

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Inactive Waste Sites and Releases

Audit Ftndlna Tltle

inadequate Remedial Investigation/ Feasibility Study WorkPlan. Low Priority Sites

Audit Ftndlna arid Aoollcable References Thedraft Remedial Invesfigaticn and Feasibility Sludy (RI/FS) Plans for LowPriority Sites (IWS-68), dated June1, 1988, doesnot addressseveral aspects required under CERCLAJSARA other relevant guidance available et the time the plan was being and produced. Deficiencies include:

1)

Lack of AdequateScoping- A scoping meeting was not held betweenthe Rocky Flats Plant (RFP)and regulatory agencypersonnelto discuss strategies and plat~ for the RI/FS(I-IWS-45). Lackof ARARs Thereis no discussionof the potential applicable or relevant and abpropdate requirements(ARARs) that will be addressed during the RI/FS.

3)

Lack of a Conceptual Model- Thereis no development a conceptualmodelfor of each of the Solid WasteManagement Unit (SWMU) groupings to assess waste sources, the nature and extent of contamination,pathways, receptors, andassist in identifying data needs. Lack of Data Quality Objectives (DQOs) Thereis no assessment the use of data for the determination of the types of chemical analyses and quality assurance/quality control requirements that wilt be applicable.

5)

IncompleteEvaluation of Existing Data - Thereare discussionson the existence of available data. but this informationis not incorporated into the sampling plan. For example, SWMU D, there is a discussion on the availability of data for Group upstreamand downstream the original landfill and ash pits; however,these of data are not evaluatedto determinedata gapsor to aid in the development a of samplingplan. Instead, the plan indicates that these data will be evaluatedas part of the RI, but then goes on to describe a sampling programwithout the benefit of data review. Lack of a Remedial Alternatives Discussion- Thereis no discussion of general response actions andalternatives to assist in identifying data needs. Incomplete Work Plan Elements Not allstandardtasks for Federal-leadsites are discussed; e.g., community relations (see rotated Finding IWS/AF-1), sample analysis,' validation, anddata evaluation. Omitted SWMUsTwelveSWMUs identified in the 3004(u) Appendixof the Part B Application (IWS-78)maynot havebeenincluded in this workplan (see related Finding IWS/AF-5). Thereis not sufficient justificafion for eliminating SWMU 171, whichis includedin the workplan, fromfurther consideration.

6) 7) 8)

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9)

Lackof Specificity in Feasibility StudyPlan - TheFeasibility StudyPlan is too generic and does not deal specifically with howthe SWMU groupings will be assessed. Citation end Reoulrements

~,pollcable

Section 104 of CEP,CLAmandates that those hazardoussubstances re~easedto the environment that present a danger to public health and welfare be respondedto in accordancewith the National ContingencyPlan (NCP) (40 CFR 300). 40 CFR 300.68 the NCP(or 40 CFR300.430 of the Oeoember 21, 1988, proposed NCP) provides proceduresfor conducting RI/FSs. The RI/FS proceduresare amplified in the Interim Final Guidance for ConductingRemedial Investigations and Feasibility Studies Under CERCLA, dated October 1988 (ERAJ540/G-89/O04). draft versions of this document Two were available before the LowPriority Sites RI/FS WorkPlan was submitted, one in October1987and the other in March1988. Recommendations

1)

The LowPriority Sites RI/FS WorkPlan should be finalized in accordance with the October1~,98 Interim Final Guidance the Final Guidance,when (or issued), and include any omitted SWMUs. Before proceeding, RFPshould incorporate ERA and COH comments, which have not yet been received (I-IWS-10, I-IWS-17, and I-IWS-18). Scopingmeetingsshoutd be held with the regulatory agencies present to plan the RI/FS. Minutes should be taken at these sessions, and all parties should agree to their contents before further work takes place in order to ensurethat there is a mutual understandingof the scope and nature of activities being performed.

3)

Sufficient time shouldbe scheduled complete work plan of high quality. This to a includes sufficient time for required internal and external review (see related Finding tWS/BMP-2).

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Document 195-13 inactive WasteSites and Releases of 36 Filed 07/27/2006 Page 25
IWSIAF-5

A~dlt F1ndlna Title

Omissionof SWMUs the from EnvironmentalRestoration Program

,&udlt Ftndlna end Ar~ollcable References TheRockyFlats Plant (RFP)Environmental Restoration programmaynot addressa~l the inactive SWMUs indicated in the appendix of the 0ecember 1987, RCRA 15, Part B Application, dealing with 3004(u)wastemanagement units (IWS-78), as required by 0OE~EPA/COH ComplianceAgreement(IWS-3). Of the 166 inactive SWMUs identified in the 3004(u) document,12 maynot have been addressedin closure plans (IWS-79) and in the high priority, medium priority, and low priority remedial activity documents (IWS-7and IWS-9, IWS49,and IWS-68). Theomitted sites are inctuded on the attached table. Sites 147.1, 147,2, 150.2, 150.4., 150.6, 150.7, and 150.8 may included in the be Original ProcessWasteLines Closure Plan (IWS-79, Volume XlV). Nowever, the 3004(u) AppendixSWMU reference numbersare not used in this closure plan and correlation between 3004(u)appendixand the closure plan is difficult. Nonetheless,based the descriptions of these sites provided in the 3004(u)appendix,they do not appearto addressed. A~#llcable Citation end Requirements

Section 8 of the ComplianceAgreementbetween DOE,EPA, and CDH dated July 31, 1986, requires RFPto identify all SWMUs to take actions related to site and characterization, corrective action, and closure for any inactive SWMUs accordance in with the schedules attached to the agreement. By June 1, 1988, all SWMUs should have been addressed. Recommendation8 Review closure plans and remedialactivities to verify that the 12 units listed in the attached table have not been included. Addressany omitted units in a revised Low Priodty Sites RI/FS WorkPlan. See related Finding IWS/AF-4.Thesesites should be incorporated into SWMU groupings, their characteristics assessed, available data analyzed,anddata gapsidentified. If it is determined that additional field studies are required, data quality objectives, preliminary ARARs, a conceptualmodelshould be and developed assist in the designof a field program. to

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SWMUs OMIT'FED FROM THE ENVIRONMENTAL RESTORATION PROGRAM" SWMU 135 137 138 144 147.1 147.2 150.2 150.,$ 150.6 150.7 150.8 198 Cooling tower blowdown Cooling tower blowdown Bldg 774. Cooling tower blowdown Bldg 779 Sewerline break Processwasteleak - Maas area Processwaste leak - Cwen area Radioactive liquid ~e~k- Wof Btdg ~1 Radioa~ve l~quid leak - E of Bldg 750 R~dioac~ve liquid leak - S of Bldg 779 Radioactive liquid le~ - S of 81dg776 Radioac~ve liquid ~eak- NEof Bldg ~9 VOCsin groun~ater

"Reference: IWS-78

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Inactive WasteSites and Releases IWS/AF-6 Aud|t F~ndlna Title Inadequate Remedial Investigation/ Feasibility Studies 881Hillside -

TheRockyFlats Plant (RFP)preparedremedial investigation (RI) and feasibility study (FS) reports for the 881 Hillside, dated March1, 1988, (IWS-7), that do not address severaJ aspects required under CERCLA relevant guidancesavailable at the time end these report~ werebeing prepared.Examples these deficiencies include: of

1)

Lz, ck of a Conceptual Model- Thereis no conceptualmodeldeveloped basedon dat~collected for the 881Hillside. inadequate Background Characterization - The 881 Hitlside Ri does not adequately characterize the background hydrogeologic setting for metals and radionuclldes. See related Finding GW/AE-2. Background characterization is necessary determinepotential downgradient to effects of the 881 Hillside. Only one backgroundwell and a one-time soil sampling event, consisting of nine samplesto a depth of one foot, were usedto characterize the groundwaterand soil backgroundlevels. A backgroundhydrogecchemicalcharacteri~ation is beinginitiated by the RFP.

3)

Poorly DefinedExtent of Contamination Thesourceof the metals contamination and the lateral and vertical extent of contaminationis not well defined. See related Finding GW/AF-I.Results of groundwater qualit~ are discussedfor the individual solid waste management units (SWMUs) located at the 881 Hillside (e.g., SWMUs 103, 106, and 107). However, there is no comprehensive discussion delineation, either vertically or horizontally, of contaminant or plumes emanating the 881Hillside in its entirety. from Insufficient Quality Assurance/Quality Control (QA/QC)- The programsand practices associated with the quality assuranceand quality control for the envir~nmenta{analyses conductedat the ~,uilding 881 GeneralLaboratory are not adequate document validity of the analytical data. Seerelated Findings to the QNAF-1 and Premature Preparationof Feasibility Study - The881 Hillside Feasibility Study was preparedprematurely. The RI used in preparing the FSdid not adequately describe the background level, or extent of contamination,and data wereof poor quality (see discussions above). Consequently,decisions made the FS were in basedon insufficient or inadequate data.

4)

RFP identified the needfor additional remedial investigation workto be performed has and a revised RI and FS will need to be produced. This will lead to a delay in remediation. However, in the meantimean interim remediat action plan is being evaluatedfor implementation.

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Section 104. of CERCLA mandates that those hazardous substances released to the environment that present a danger to public health and welfare be respondedto in accordancewith the National ContingencyPlan (NCP)(40 CFR 300)° 40 CFR 300.68 the NCP(or 4(3 CFR300.430 of the 0ecember21, 1988, proposed NCP)provides proceduresfor conducting RI/FSs. The RflFS proceduresare amplified in the Interim Final Guidancefor ConductingRemedialInvestigation and Feasibility Studies Under CERCLA, dated Qctober1988 (EPA/~40/G-89/004). draft version of this document A was avalla33{e in October 1987, Section 12.f. af the Compliance Agreement betweenDOE, EPA, and CDH,dated July 31, 1986, requires that the RFRshall use CDH ERAor approvedQA/QC chain-of-custody procedures. and Recommendations 1) Prepare final RI ~ndFSreports in accordance the latest RI/FSguidance. the with Incorporate the results of the ongoing background hydrogeochemical oharacterization (IWS-45)into the final RL Since the remedial investigation process can be performedin phases, additional data collected from existing wells, future wells, and any other samplingshould also be incorporated. FStasks dependent RI data should be performedonly after the RI data have on been fully evaluatedandare of goodquality. Detailed minutesshould be taken at all meetingswith regulatory agencies. All parties should agreeto their contents before further work takes place to ensure that there is a mutual understandingof the scopeand nature of the activities being performed. Sufficient time andresourcesshould be allotted to completea RI and FSof high quality. This includes sufficient time for required internal and external review. See related Finding IWS/BMP-2.

2)

3)

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Inactive WasteSites and Releases IWSiBMP-1 Lackof a Unified Spill Reporting and Notification Procedure

The RockyFiats Plant (RFP)does not havea unified spill reporting and notification procedure. Instead, it has several procedures which were developedfor different purposes and havedifferent approaches. These procedures,include the following:

1)

The Hazardous and Mixed Waste RCRA Standard Operating Procedures 11 HazardousSubstance/Waste Spill Response RCRA and Spill Use Kit (SOPHW-11)(IWS-24} was developedas part of the RCRA Part B Contingency ,alan. In this procedure, the discoverer of the spill is to notify the Shift Superintendent.Eight scenarios havebeendeveloped notification, but in for cases, "one pint or one pound" matedaJ of spilled is usedas a guideline for spill reporting. Depending the type, location, and size of the spill, the Shift on Superintendent is responsible for calling the RCRA/CERCLA office. The latter group, in turn, determines whetherthe spill is of a reportable quantity, end if necessary, notifies the DOE Rocky Flats Office Environmental Branch, which not~fies the National Response Center. The DOE RFAO Environmental8ranch hes its ownincident notification procedure (IWS-17) in which members that branch, upon notification of a reportable of quantity release, are to contact EPA,COH, the National Response and Center. RFAO Order RF 5000.3, UnplannedEvents Notification and Reporting System (IWS-57)establishes responsibilities within RFAO investigating, evaluating, for reporting, and correcting unusual occurrencesand unplannedevents such as environmental spills. A hierarchy of reporting is provided,including notifications to the Shift Superintendent,the Staff Duty Officer, RFAO, the ALPand DOEand HQEmergency Operations Center. However,no mention is made notification of to the National Response Center. DOE Order 5500.2A, Emergency Notification, Reporting, and Response Levels (1WS-67), requires DOE field elements to notify the HeadquartersEmergency OperationsCenter and the National Response Centerafter discovery of environmentalreleasesof hazardous rnatedals in excess reportable quantities. of Chapter 4 of the RockyFlats Emergency Plan (IWS-34) contains information notifications in the event of emergencies. provides a hierarchy of reporting It environmental releases on-site, including the Shift Superintendent, the site Emergency Operations Center, ALP, and county and state agencies, although specific contactsand triggering quantities for notification are not provided. In addition, specific proceduresfor notifying the National Response Center and DOE-HQ not covered. ere

2) 3)

6)

The Spill Prevention, Control, and Countermeasures/Bast Management Practices (SPCC/BMP) Plan (lWS-18) was developed for NPOES-permitting purposes. AppendixII of the seconddraft revision (May 1989) indicates that the Shift Superintendent authorized to cell the National Response is Centerand the local
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emergency planning commission and that Environmental Managementis responsible for determining whether the volumecf the spill iS a reportable quantity.

7)

Finally, each major building has its own Emergency Plan, for example the building 771 Emergency Plan (IWS-33). This particular documenthas proceduresfor local notification of spills. Major(larger than 10 gallons) hazardous material spills are to be reported by calling the site emergency number while minor spills (less than 10 gallons) can be cleaned up at the direction of the supervisorand Industrial Hygiene, accordingto RCRA criteria. BMP and Recommendation

At~ollcable

Section 103(a) of CERCLA {imp{emented 4(] CFR by 302), Section 3Q4. of SARA Title (implemented by 40 CFR3.55), and DOE Order 5500.2A require that the National ResponseCenter, local and state emergencyplanning commissions, and OOE-HQ Emergency OperationsCenter, respectively, be contactedin the event of certain types of environmental spills. To ensure that proper notifications are made a consistent in manner that all site personnel understandthalr responsibilities, the site should and develop one unified procedure for spill reporting and notification. Of the seven procedures discussed, SOPHW-11 is the most comprehensive and should be developed include all requirements, to including SARA T~tle III, Section304 notification and follow-up. In addition, consistencywith this procedure should be maintained all in other required plans and orders. Theunified procedureshoutdinclude applicable steps to be taken from the time the release is first detected to the time DOE notifies the appropriate authorities. Specific responsibilities and emergency contacts should be defined. Theunified procedure will assist in ensuring that the appropriate parties are notified andthat there is site-wide coordinationin responding releases. to RFPis doing several things to improve spill reporting procedures. An Emergency Preparedness TaskGroupis in the process of being established to develop a unified spill responseprocedure (l-IWS-26 and I-tWS-29). The SPCC/BMP is under review plan and changes that will make consistent with SOP it HW-11 (I-IWS-21) are anticipated. internal letter was sent by RFPmanagement May 12, 1989, to all employees on remindingthemof procedures reporting hazardous for material spills (IWS-36).

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Inactive WasteSites and Releases IWSiE]MP-2 Inadequate]Smefor Preparation and ReviewCycle for Environmental Restoration Documents

Internal (DOE RockyFiats Plant [FIFP]) and external (CDH EPA)written reviews and and of RFPenvironmental restoration documentshave not been performed in a timely manner, at aJl. In addition, field work, data analysis, and document if preparation have proceededon an aggressive schedule without the benefit of reviewer's comments, in order to meet schedules in the DOE,EPA, and CDN ComplianceAgreement(IWS-3). Consequently,conclualons made and decisions reachedhave not necessarily received the approvalof regulatory agencies. RFPhas produced numerousdocumentsdealing with the remediation and closure of inactive SWMUs, including remedialinvestigation/feasibility study (RI/FS) workplans, and FS reports, and closure plans. Some these studies have been performedunder of ambitious schedules. For example,work plans for the 881 Hillside RI and the 903 Pad, Mound East TrenchesRI were submitted in February 1987 and the RI reports were and submittedon July 1, 1987and December 1987; these dates wereset forth in the July 31, 31, 1986, ComplianceAgreement. In several cases, these documents werereviewed and written comments were provided, as indicated in the attachedtable; this list is not all-inclusive. In all but oneof the documented cases of internal DOE reviews, their written comments werenot submitted to RFP until after the reports had beensent to the regulatory agencies. For certain reports, verbal comments were provided by DOE before reports were submitted, but there wasnot adequate time for DOE perform a comprehensive to review (I-IWS-11, I-IWS-27). A similar situation existed with reviews betweenRFPand subcontractors performingremedial work (I-IWS-45). External written reviews from regulatory agencieswere also not provided in a timaly manner, at all, as indicated in the attachedtable. In order to keepto the schedules if set forth in the July 31, 1986, Compliance Agreement (IWS-3), the site choseto continue with the next phase remedialworkrather than wait for comments; example High of for the Priodty Sites RI andrevised RI andFSreports (I-IWS-17, I-IWS-18,I-IWS-23,I-IWS-27 ). A#ollcable BMP and Reoommendatlons

Currentindustt~ practices for the productionof remedialresponse documents Federal for facilities include internal quality assurance/quality control reviewby the contractor(see related F~nding GW/AF-4) and review by the agency for which the work is being performed before the document released. After all comments incorporated and the is are document released, regulator 7 agenciesgenerally request a 30-day review cycle. is DOE-Headquarters requestedthat they be allowed a 21-day review period for RI/FS has Work Plans, draft andfinal RI/FSreports, proposed plans, and the draft andfinal records of decision (IWS-86). RFO requesteda 30-daysimultaneousreview period. has (I-IWS-11). CERCLA Section 121(f)(1)(E) requires that states be given a reasonable opportunity to comment remedial responsestudies. Section 12.c, of the Compliance on Agreement states that certain DOE submittals shall be provided to EPAand CDH for

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comment weekspdor to the scheduleddate and that a final submittal by DOE. two which incorporates EPAand COH comments, provided by the later of the scheduledeadline be or sevendaysafter DOE's receipt of the comments, whichever later. is

t)

Develop realistic schedules the performance RIs and FSs, incorporating all for of requestedand required review cycles, at the inception of a project. Presently, EPA anticipates that RI/FS studies should t~ke approximately12 to 18 monthsto complete.In actuality, many RI/FSsare taking 2 years to complete.Suchscheduling is presently being included in the Long-Range EnvironmentalRestoration Schedules RockyFlats (IWS-87). for Establish an internal QNQC programto ensure that the documents complete are and of the highest quality. See related Rnding GW/BMP-4. Allowances should be made this in project schedules. Comments for should be submittedin writing; any verbal comments should be documented writing and all parties should in agreeto their contents. If the review or the QNQC processis delayed, the report should not be released, andthe next phaseof workshould not be initiated until comments have been received and incorporated.

2)

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WRITTEN REVIEWS OF ENVIRONMENTAL RESTORATION DOCUMENTS

DOCUMENT Draft Community Relatlone Plan (IWS.42) CEARP Phase Ih Bite Spe¢lft¢ Monitoring Plan (IWS-5, IW~-B) RI Report for High Priority Sites (IWS-4)

DOCUMENT SUSMI3"TAL DATE (To Regulators) B/88

DATE WRITTEN COMMENTS SUSMII"~ED (To RFP} none none

COMMENTING AGENCY EPA(I-IWS-10, I-tWS-22) CDH(I-IWS-~'2) ODH(I*IWS-~, I-IWS-1 0) EPA(IWS*83)

2187

none 4/87

7/1/87

8187 10/1 4/87

EPA-Pteilm~nary (IWS-37) EPA/CD H-Final (IWS-38) EPA(IWSo56) RFAO(IWS-52)

903 Pod, Mound, East Trenchee Raport(IWS-4g) 081 Hillside Revised RI(IW~-7} end FB(IWS-g) Bldg. 443,No. 4 Fuel OII Tank Closure Plan (IWS-S5) Low Priority Bites RI-FS Work Plan Phase 11 903 Pad, Mound East Trenchee Sampling Plan (IWS-54) Solar Evaporao tIon Pond Closure Plan

12/31/87

3125188 8/33/88

3/1/88

6101/88 8/31/88 9123188 9/09/88

RFAO(IWS-40) EPAICHD(tWSo41) DOE-HQ(IWS-47) CDH(IWS-74)

416/88

6/1/88

none none

EPA(I-IWS-34) CDH(I-IWB-17, I-IWS-1 8) RFAO EPA/CDH(IWS$-66)

6130188

8/30/88 11/30/88

8/1/88

6/30/88 11/29/88

RFAO(IWSo73) CDH(IWS-71)

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IWS/~MP-3 August 1989

Inactive WasteS;tes and Releases IWS/BMP-3 BMPFlndln~ Title BMP Ffndln~ The Rocky Flats Plant (RFP) currently uses a cumbersome time-consumingmethod and for determiningthe amount toxic chemicalsthat a~e manufactured, of processed,or used. In 1988, three teamsof two peopleconta~ed chemicalusers andwith the use of barall coding devices, inventoried the chemicalson hand. Theresulting lists of chemicals were sent back to the users, and they were asked for annual usages and maximum amounts on hand during the year. Oncethe lists were returned, MSDSs were searchedby hand to identify the individual components the toxic chemicallist that werein tradename on mixtures. Total amounts toxic chemicalsmanufactured, of processed,or usedwere then calculated and compiled, and compared the threshold quantities in SARA to Title III, Section 313, (IWS-32and I-tWS-20). ADoltcable BMP and Recommendations Determinationof ThresholdAmounts for SARA Title Iit Section313 Reporting

SARA Title 111, Section313(implemented 40 CFR by 372) requires that ce~alnfacilities, such as RFP,report emissionsof toxic chemicalsthat are manufactured, processed,or used in excess of certain threshold quantities. The first step in this process is determining which toxic chemicals, if any, are manufactured,processed, or used in excess of ~e threshold amounts.

1)

RFPshould implementa systemin which lhe inventory of annual usageis tied into the procurementsystem. Thus, toxic chemical usageestimates could be developed throughout the year basedon a record of purchases,rather than on a manual system inventoryingall facilities at onepoint during the year or obtain of estimatesfrom users. This systemwouldbe automated, less labor intensive, and moreaccurate than the system used in 1988. A system such as this is being implemented the Industrial HygieneInformation SystemsGroup(I=IWS-44). by Another system that could be used is the one addressedin Finding WM/BMP-8, whichdeals with procurement control for regulated materials. In addition, the RFP should continue, and possibly accelerateits presentprogram of entering the MSOSs the nearly 12,000chemicalson site into a data. base; of presently 2,000 havebeen entered. This wouldsimplify the task of developing inventories of toxic chemicals whichare containedin tradename mixtures.

2)

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IWS;BMP-4

Inactive WasteSites and Releases tWSiBMP-4

BMPFlndln~ Title

Repriodtization Ihe OriginalLandfill of

TheC-series ponds, which ere dcwnstream the original landfill, are scheduledfor of remedialactivities beforethe landfill. This couldresult in reccntamination the ponds of if there is contaminant runoff to the ponds dudng remediation the old [a~dfill. of Theoriginal landfill is situated on a slope that drains to Woman Creekand is 300 feet from the creek. TheSouthDiversionDitch cotlects runoff and leachate from the landfill and carri