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

Case 1:91-cv-01362-CFL

Document 195-10

Filed 07/27/2006

Page 1 of 37

Exhibit 26-A

Case 1:91-cv-01362-CFL

Document 195-10

Filed 07/27/2006

Page 2 of 37

Section

Case 1:91-cv-01362-CFL

Document 195-10

Filed 07/27/2006

Page 3 of WATER 37 ~URFACE
August 1989

3,0 o SURFACEWATER SCOPE OF AUDIT 1. Review Issues Related to NPOES Permit a~ Conformance record under existing permit b. ¢. d. e. 2. Impact of proposedagreement satisfying requirements on Sampling & monitoring review Wateranalysis provisions - Quality Assurance/Quality Control Review procedure notification of permit violations for

Sewage Treatment Plant Issues a. Adequacyof present system (weekdaysvs. weekends) b c. d. Reviewprocess waste water sources and pretreatment systemsfor possible minimization or modification Recommend possible improvementsto operatJng procedures Investigate possibleadditions to retention basinsto contain spills or unusual occurrences

e. Sprayirrigation and its impact on groundwater/surface water issues 3. Spill prevention and control measures a. b. Reviewfor adequacy and complete[~ess Investigate potential for eliminating pathways sanitary sewercollection to system

c. Consideradditional monitor/alarm systemsfor tanks 4. Ddnkingwater issues a. Backflowprevention measures installation and inspecSon

b. Potable water treatment records, including testing

Case 1:91-cv-01362-CFL

Document 195-10

Filed 07/27/2006

Page 4 of 37

SURFACE WATER August 1989

SURFACE WATER FINDINGS

SW/AF-1 SW/AF-2 SW/AF-3 SW/AF~. SW/AF-5 SW/AF-6 SW/AF-7

Discharge Monitoring ReportDeficiencies Need for Certified Operatorsat Sewage TreatmentPlant UnpermittedDischargesfrom East and WestGate GuardPosts Quality Assurance Surface WaterSample Collection, Handling, and Documentation Sewage TreatmentPIant Deficiencies Work Order Lag Time Deficienciesat the SprayIrdgafion Site

EEST MANAGEMENTPRACTtC~:~ SW/BMP-1 SW/BMP-2 SW/BMP-3 SW/BMP-4 SW/BMP-5 SW/BMP-6 Deficiencies in Draft Best Management Practice Spill Prevention Containment end Control (BMP/SPCC) Plan Lack of Flow Measurement C-1 Pond at Inadequate Protocolsfor TimelyIdentification of Pollutant Releasesto Sewage Treatment Plant Cooling TowerBlowdown Building 774 at D~.m inspection Reports Laundry Operations

NOTEWORTHY PRACTI(~; sW/NP-1 Utilities Operations at Buildings 371 and 374 Complex

3-3

Case 1:91-cv-01362-CFL
Audit Dlscloltne Audit FIndlnd

Document 195-10

Filed 07/27/2006
SuraceWater

Page 5 of 37

Number

SW/AF1 DischargeMonitoring Report 0eficiencies

~ldlt Flndtnc~ Tltfe Audit Ftndlnd and Ao~llcable

Monitoring of flow rates and oil and greaseconcentrations is not being performedin the manner defined in NPDES Permit Number (;0-0001333. For outfail 001 (S-3 pond discharges), the permit requires that, "The dates, duration, and approximatevolume discharged eachdischargeshall be reported." (;urrently the plant reports only the for dates of discharge, the averagedaily flow for the month, and the maximum daily flow during the month. For outfail 002 (A-3 pond discharge) the permit requires daily monitoring, "whenthere is a dischargeand/or a bypass."Theplant reports outfail 002 flows in the same manner 001. Plows for outfails 005, 006, and 007 are correctly as reportedoncea year in the formatsrequired by the permit. The deficiency in reporting oil and grease concentrations is causedby an apparent anomalyin the permit for outfail 001. Page4. of the permit requires that, "The concentration of oil and grease shall not exceed mg/l in any grab samplenor shall 10 there be a visible sheenor floating oil in the discharge." However, Page6, where on the self-monitoring requirements outfati 001 are listed, the oil andgreasefrequency for waslisted only as a daily visual observation,with no referenceto the grab sample cited on Page4.. The plant has only reported visible sheenobservations on its Discharge Monitoring Reports. Appllqal~le ~ltal;lon and Requirements

U.S. EPA NPDES Permit No. CO-000133, dated 11/26/84: Flow Measurements: Outfail 001, Section A, Paragraph Item b, Page7, specifies requirementsfor flow 2, monitoringat Outfail 001. U.S. EPA NPDES Permit No. C0-000133, dated 11/26/84: Plow Measurements: Outfail 002. Section A, Paragraph Item a. Page8, specifies requirementsfor flow 3, monitoringat Outfail 002. Oil and GreaseConcentrations: Outfall 001, Section A, Paragraph1, Page4., sets concentration limits for oil andgrease Outfall 001. at Oil and GreaseVisual Sheen:Outfail 001, Section A, Paragraph2, Page6, sets visual inspectionrequirement oil andgreasesheen (~uffail 001. for at Recommendations Eventhough the revised permits (currently being negotiated) maychangecertain these requirements, the plant should report flow volumesfor eac~ discharge from outfalls 001or 002as required by the permit currently in effect. Provisionsshouldalso be madeto collect, analyze, and report concentrations of oil and grease in the discharge from outfail 001 to measurecompliance with the maximum concentration limit of 10 mg/l in anygrabsample stated on Page of the permit. as 4.

3-5

Case 1:91-cv-01362-CFL

Document 195-10

Filed 07/27/2006

Page 6 of 37
August1989

Surfaca Watar ~udlt F~ndlna Numbe~ Audit F~ndlna Tttf~ S~AF-2 Need Certified Operatorsat For Sewage Treatment Plant

Existing labor agreements, causeuncertified operatorsto be assignedto control may sewagetreatment plant operations. This would be inconsistent with Colorado Department Health requirements. The present certified operator maybe bumped of by any candidate senior to him whowantsthe steady daytime schedule. This would be inconsistent with state certification requirementsfor sewage treatment plant operators. Aooltcable Citation and Requirements

Colorado Department Health Water Quality Control Regulations as provided in of Article 9, Title 25, C.R.S. 1973, 25-9-101at paragraph 100.9.5 and 100.10indicate the requirementsfor certification of sewage treatment plant operators at municipal andindustrial sites, anddescribes qualifications for certification. the Rec0mmenda~ion~ Require certification of all candidates sewage for treatmentplant operatorpositions.

2)

Negotiatewith unionto ensure that potential candidates the for sewage treatment plant operatorposition be limited to certified operators.

3-7

Case 1:91-cv-01362-CFL

Document 195-10

Filed 07/27/2006

Page 7 of 37
SW~'AFo3 August 1989

Surface Water Audit FindlFld Number SW/AF-3 Unpermitted0ischarges from East and WestGate GuardPosts

Audit Flndlna Title Audit Finding and

Treated sewage from the East and West Gate Guard Posts is released to the subsurfacenear eachfacilib/; the leach fields are inadequateand sewage emerges on the surface, flowing to nearby streams under someconditions. Neither of these sources is currently covered by the NPOES permit. The practice was questioned during the DOE Environ-mental Survey but the site respondedthat neither source discharged, "to any navigable streamor water bodyand therefore are not regulated or required to be regulated under the NPOES permit program" (SW-24). However, the definition of navigablestreamhas beeninterpreted by U.S. EPA RegionVIII to include all tributaries of streams which could be considered navigable. Under this interpretation, Woman Creek and Walnut Creek, and their tributaries may be considerednavigable. Also, a report titled, Scope EastPNest for GateSeptic Systems, November 1988, (SW-23) reads, "The facilities are currently dischargingto tributaries of Woman CreekJStandley Reservoir (West GuardPost/120) and to Walnut Creek/Great WesternReservoir (East GuardPosti920), Theseflows do not reach the reservoirs surfaceflow unlessthe flow is enhanced precipitation/run-off. by A~ollcable Citation and Requlrement~

The General Provisions for requiring an NPDES permit are given in 40 CFR401. Specific definitions of =point source" and "navigable water" are given at 40 CFR 401.11(d) and (1), respectively. The DOE Environmental Survey cited above is Environmental Survey Prelimina~ Report on Rocky Flats Plant, Golden, Colorado, dated June1987. Thespecific reference to this finding occurs in Section 3.3.4.4.1, Page 3-68. The site's response was found in the "Implementation Plan for EnvironmentalSurvey Findings, Revision 1.0, RockyFiats Plant, Golden, Colorado. February1988, Page2.3.2. The discussion regarding destination of flows from the guard posts is found in the "Scopefor East/WestGate Septic Systems"prepared by RFP'sFacilities EngineeringDepartment November in 1988, Page3.

The sewage should be collected in tanks and then transported to ~n available manhole for transfer to the sa, nitar7 sewage collection system while plannedmodifications are being investigated. During this period no permit is necessary since the existing sewageplant operations are covered by the current NPDES permit. At such time as improvedpackage treatment systemsmaybe installed at the guard posts, steps wilt haveto be taken to apply for appropriatepermits. It maybe in the best interests of RFP to continue collecting the sewagerather than assumingthe cost of replacing the existing system. Theseactions wouldpreclude the need for capital expenditures to replace the existing systems, and alleviate ~heneedfor permits to dischargefrom these
sources.

3-9

Case 1:91-cv-01362-CFL

Document 195-10

Filed 07/27/2006
Surface Water SW/AF-4

Page 8SW/AF-4 of 37
August 1989

Title

Quality Assurance Surface WaterSample Collection, Handling, and Documentation

AF Ftndlno and- Aoollcable Sample collection, handling and documentation procedures with regards to the surface water samplesare inadequate and could potentially introduce contaminants into samples,or result in naccurate analytical data. The following werenoted during a review of surface water samplingprocedures:

1)

Thesamplingtechnician wasnot workingfrom written procedures.The written proceduresfor the acquisition,handling, and preservation of surface water samplesare being revised and are not available to the sample technician (I-

sw-12).

EPAsample handling and preservation procedures require that samples be kept cool after acquisition (4 degreesC). The cooler which contained the surface water samplesacquired during the review did not contain ice or any other refrigerant, andtemperatures werewell above4 degreesC.

3)

The samplebottle caps werenot lined with Teflon as recommendations EPA by sampling procedures. Composite samples werenot thoroughly mixedprior to splitting into individual sample bottles. Failure to properly mix compositesampleswould adversely affect such analyses as total suspended solids (TSS), biochemical oxygen demand (BOID), and chemical oxygen demand (COD). SamplepH is measuredin the field and subsequently checkedby a sample receiving clerk after addition of preservation reagents (acids). Both measurements were done by immersingthe pH test strip into the sampleand reading the color change.This method pH measurement the potential to of has introduce contaminants directly into the samples.

6)

Theparameters interest for a sample of are not noted on the sample container. Theparameters noted on the sample are label whichis placed in a clear plastic envelopeand attached to the neck of the sample bottle with a rubber band. If the rubber bandbreaksand/or the sample label is lost, the intendedparameters would not be known the sampleinvalidated. and The chain-of-custody is signed and dated by the sample technician upon receipt of the sample the laboratory instead of when by the actual sample was collected. The intent of ct~ain-0f-custody is to document the custody or possession of samplesfrom the time of acquisition until transfer to the laJ:~oratory.

Case 1:91-cv-01362-CFL

Document 195-10

Filed 07/27/2006

Page 9 of 37

1)

40 CFR136.3, Surface Water Sample Preservation, Table II - Required Containers, Preservation Techniques, and Holding Times presents the sampling handling and preservation requirements for NPOES samples. A footnote to the table says that "sample preservation should be performed immediately upon sample collection." The majority of the preservation requirements indicate "Cool to 4. degrees C."

BP~commendatlons

1)

2) 3} 4)

A written procedure the acquisition, handling, anddocumentation surface for of water samples should be developed. The procedure should follow the EPA sample acquisition protocols with respect to sample refrigeration and preservation, samplebottles and caps, and chain-of-custody, Refer to the Handbook for Sampling and SamplePreservation of Water and Wastewater, EPA-600/4-82-029, 1982, for details on these protocols. Theparameters interest should be noted on the samplecontainer in order to of eliminate confusionor miaidentification of intendedparameters. Composite samples should be thoroughly mixedprior to splitting into separate samplebottles. pH should be measured an aliquot of the sampleand not directly from the on sample bottle.

3-12

Case 1:91-cv-01362-CFL
Audlt Dlsctoltne AF Flndln~

Document 195-10

Filed 07/27/2006
Surface Water SWIAF-5

Page 10 of 37 SW/AF-5
Auguat 1989

Number

Sewage TreatmentPlant Deficiencies Audlt F3ndlnd and Aoollcabl~ The Sanitary Waste~Nater Collection System TreatmentFacility at RFP several and has deficiencies whic~preventit from achievingoptimum efficiency in purifying wastswater. Theseare describedin detail in a separate report included as Appendix The major B. deficiencies maybe summarized follows: as

1)

The cyclic nature of the infiuent flow to the sewage treatment plant at RFP inhibits efficient operationsof the plant Surges flow occurin late afternoon in with minimum flows (and incomingorganic matter) throughout the night and weekends holidays. or The collection system may have undetected pathways whereby toxic or ha~'.ardousliquids may enter the systemand poison the organisms which the on treatmentplant relies (e.g., the accidental releaseof chromic acid solutions in February 1989 through the 444 E~uilding foundation drain connectedto the sanitar7 sewersystem).

3) 4)

Thesludge drying beds. with one exception, rest on a tamped soil baserather than an impervious foundation. This mayafford a pathwayfor the sludge liquids to penetratethe soil and potentially contaminate groundwater. the Monitoring alarms and remotecontrol equipment are inadequateto operate the STP the mostsafe and efficient manner. in Alarmscurrently installed are not routinely tested and maintained. No methodof off-shift personnel alarm notification exists. Operatorcoverage not providednearly three-fourths of the time. A full-time is certified operator is available only during the day shift Monday throughFriday. Therest of the cycle is coveredby water treatment plant operators on a very limited basis, no more than 1 or 2 hoursper shift. Theoperator is often forced to do without equipment necessaryfor effective treatment due to long turn-around times for maintenance on work order requests. Seerelated finding, SW/AF-6. Thereis insufficient analytical data on sewage treatment plant infiuents to propedymodity operating procedures ensuremosteffective treatment. to Thepresent aeration basin mixers maynot be providing sufficient agitation of the basin volumesto ensure completetreatment, inspections dudngthe audit indicated that there are poorly mixedareaswithin eachbasin.

Al~r~llceble

Citation

and Requir~m~nt~

The current NPDES Permit NumberCO-0001333requires at Part I1, Section A (Management Requirements)paragraph 3 (Facilities Operation), Page17, that

Case 1:91-cv-01362-CFL
SW/AF-S August1989

Document 195-10

Filed 07/27/2006

Page 11 of 37

permitteeshall at all times maintainin goodworkingorder andoperateas efficiently as possibleall treatmentor control facilities or systems installed or usedby the permittee tO aohieve compliance with the termsand conditions of this permit." Reccl~endatlons Several specific recommendations included as part of t~e separatereport attached. are With respect to the deficiencies cited above, the following options should be considered: - -

1)

The current flow minimization effort at washrooms, showersand toilets which has reducedflows at B-371/374by 12-18% should be expanded facility wide. Theremote controller for the flow restriction valve at B-990shouldbe repaired. The infiuent organic loading should be definitively determined and supplementedas necessary. An ongoingproject designedto identify all connectionsto the sanitary sewers should be completedas soonas possible.

3)

Theremainingsix sludge drying bedsshould be replaced with facilities imperviousbases a~d moreefficient dewateringarrangements.

having

Waterlevel detectors alarmedto Building 995 should be installed. A hydrogen. sulfide alarm shouldbe installed in Building 995to ensureoperatorsafety. The Building 995 remote controller for the flow equalization valve should be repaired. The automatic backwash sequence the filters should be repaired. on Status alarms or additional gas cylinders should be installed in the chlorination/dechlorination system. All alarms should be subject to routine inspection and maintenance.An alarm paging systemfor off-shift personnel should be investigated. The air lift blowers should be equippedwith a power failure alarm. Consideration should be given to increasing the amountof State certified operator coverageto the sewage treatment plant. See related Finding SW/AF2.

6)

Operatorsshould request that priority attention to be given to maintenance workorders to expedite repair/replacement of defective equipment. The Maintenance Procedures Manual defines Suffix Code 550 as applying to "Essential repairs, revisions and/or additionsrequiredfor fire, safety, health or ecology', andassignsthis codeto the highest pdodtycategory. The near-termprogramto gather influent data has beeninitiated and will be completedin September 1989. Appropriate parts of this programshould be continuedin the future to gather supplemental data. If additional study of sewage treatmentplant operationswarrant, replacement of the existing aeration basin mixersmaybe necessary,

Case 1:91-cv-01362-CFL
Audit Dlsciollne

Document 195-10

Filed 07/27/2006
Surface Water SW/AF-6

Page 12 of 37
~,ugust 1989

AF Find!no Title Audlt Flndlno and A~altcable Reference

Work Order Lag T;me

Theinadequate use of the priority systemfor work order requests for the wastewater systemresults in inefficient operations. Delay in completingwork order requestswere observed a number different facilities associatedwith surface water control and at of treatment. Onsomeoccasions, several monthselapsed until the work order request was fulfilled. Examples maybe found in sewage treatment plant operator logbooks, building utilities manager's records, environmental analysis and control record surface water and NPDES logbooks, and personal interviews with RFPstaff. There is a maintenance workorder priodty systemon-site, but it appearsmostrequesters are not awareof howit functions. Specific examples delays in responding workorder requests include, but are not of to limited to the following:

1)

Automatic blowdown control for Building 559 cooling tower has been inoperative since February 2, 1988. Work orders were submitted 17 months ago, and again 10 monthsago. No action yet. Thereare at least 11 outstandingworkorders for maintenance items at Building 990 and 995, the sewagetreatment plant. Work order numbersrange from #561245 (relocate sludge sprinklers) to #573460 (install comminutor Building at 990). Several requestswerefor items designed improveplant efficiency. to

3)

Requests for maintenance cleanup of the site's pondsand damstypically and take months to fulfill. For example, inspection at C-1 Pondrevealed an inoperative pump July, and a work order repair request was submitted on in July 30, 1987. The pump was not repaired, but was eventually replaced on October8, 1987. Six months elapsed between acquisition and installation of several flow meters for the pondsystems.OnFebruary3, 1987, plans were" to install flow meters as soon as manpower and weather permit" (notes in surface water/NPOES logbook).Actual installation occurred late in July of that year. A request for sand bags to prevent pond waters from overflowing was made on March9, 1987. A repeat request on March31, 1987 received no response. 8y April 8, 1987water beganto flow over the spillway, so there wasimmediate action to the requestthat day.

4)

Aoollcable

Citation

and Reauirements

RFP's NPOES permit no. CO-0001333 at Part II, Section A, (Management Requirements), paragraph (Facilities Operation)requires that "Thepermittee shall 3 all times maintain in goodworking order and operate as efficiently as possible all treatmentor control facilities or systems installed or usedby the permitteeto achieve compliance with the termsand conditions of this permit."

eW/AF-6 Case 1:91-cv-01362-CFL Augu=tlgSe

Document 195-10

Filed 07/27/2006

Page 13 of 37

In the RFPMaintenance ProceduresManuai, Section 3.1, AppendixII, page1, there are L.al~or Suffix Code Definitions whichwouldallow for prioritizing essential repairs requiredfor fire, safety, health, or ecologysleeveroutine maintenance activities. Since mostof the abovework orders are for items essential to maintaining compliance with environmental regulations, they shouldquaiify for priority processing. the request:ere If are no~: ~zwarethat such a priority systemexists within the Maintenance Department, they shouldbe infor_m_ed the availability of reasonaJ=le of waysto get prompt:action. Discussions with users familiar with the systemindicate pdority repairs are typically accomplished within a few days to one week,so the systemdoeswork.

3-16

Case 1:91-cv-01362-CFL
Audit Dlsclollne AF Findtn~

Document 195-10

Filed 07/27/2006
Surface Water SW/AF-7

Page 14 of 37 1989

Number

= AF Flndlna Titl~ Audit FTnd{na and Aooltcable Reference

Oeficiencies at the Spray Irrigation Site

The Spray Irrigati-5n Site is not operated in acoordancewith good engineering practices. Thereare instances of pondingor sheet flow from the spray irrigation areas usedto disposeof treated sewage plant effluents from 1~-3 Pond,indicating that the systemdoesnot havethe capacity to retain all the water released there. Thearea [s underlain by an impervious,tightly cemented caliche layer whichwill not permit rapid downward migration of water. The natural vegetation presently encouragedto grow on the site is not suitable for optimum evabotranspiration waterto the air. Asa result, of only a limited volume water (less than the amount of actually dischargedthere) can expected penetratethe soil or be evaporated/transpired the air. to ~o A~c~tlcable Citation and Reouirement~

The current NPDES Permit No. CO-000133 Part I, Section A, paragraph 1 states at that..."spray irrigation (must be ) donein accordance with goodengineeringpractices with the existingfacilities. Recommendations Thespray field area capacity should be improved fracturing the caliche layer by that is impeding infiltration. Thealluvial soils in the sprayfield areasare underlain by a tightly cemented caliche layer, a naturally occurringmineral precipitate that forms[n shallowsoils in arid climates. Observations test pit trenchesin the of area by the Audit Tern indicate the caliche layer is between depths.of one to the five feet. The shallow depth of the layer allows access by heavy earth work equipmentto breakupthe oaliche by ripping or by explosives. The preferred method ripping by using a large crawler tractor with long shanksingle dpper. is This method wouldlikely provide higher production than blasting, and far less disruption to traffic andplant operationsthan blasting froma constructionsafety standpoint. Additionally, the spray field area could be ripped in one area while other areas are operated, and workmen reposition the effluent plumbinglines in other areas near the ripping operation. Blasting operations would require periodic disruptions to the spray field operation and reduction of non-blasting personnelin the work area wouldbe required for safety reasons.

2)

Thearea shouldthen be seeded with a sacrificial crop such as alfalfa or corn to optimizethe evapotranspiration water to the air andminimizethe potential for of anyrunoff from the area.

3-17

Case 1:91-cv-01362-CFL
Au~L Dlsciollne

Document 195-10

Filed 07/27/2006
Surface Water SW/BMP-I

Page 15 of 37

BMPPtndt~:L Number

Deficiencies in Oraft Best Management Practice/Spill PreventionContainment and Control (SMP/SPCC) Plan BIll = P~ndlnq The draft (second revision May1989) of ~e 8MP/SPCC is an improvementover Plan the certified 1985revised plan. Several of the sections contain inadequacieswhich could be considereddeficient by the regulator and the user. For example:1) instead of showing certification pagewith an imprinted professional engineer's (P.E.) seal, a the revised draft merelycontainsthe statement that the plan wasreviewed a P.E.; 2) by Sections7.0 - Equipment, 8.0 - Materials, refer to the Fire Department custodian and as andprovider of suchnecessities, without identifying just whatis considered essential to the program; 3) Sections 11.0, Good Housekeeping, and 12.0, Environmental Management Surveys and Inspections, are completely missing from the draft copy reviewed. ~lloable BMP and Recommendations

1)

Include a certification page whereon registered professional engineer who the reviewed plan could imprint his seal andsignature. the Provide lists of Equipment Materials for use in emergencies Sections and for 7.0 and8.0, respectively.

3)

Incorporate missing sections 11 - GoodHousekeeping 12 - Environmental and Management Surveysand Inspections after appropriate review.

Basic requirements for developing a BMP/SPCC are stated in 40 CFR Plan 125.104, paragraph(c). There are two sets of guidancefor preparing BMP/SPCC Plans, namely Publication P8-88-239/73, U.S. EPARegion X GuidanceManualfor Development of an Acceptable Spill Prevention Program, dated February 1986, and U.S. EPA Publication EPA-600/9-79-045, the NPDES 8MP Guidance Document, dated December1979. Also, in RFP's NPDES Permit, No. C0-0001333, Part Ill, Other Requirements,a Management Practices Plan section provides an outline of the Plan required to be submitted along with the NPOES permit renewal application. Oneof the missingsections, Section 11.0, Good Housekeeping, a required part of the Plan. is AdditionaJ versions of SPCC BMP and Plans have been developedby RFPstaff. Refer to CERCLA Finding CERCLA/BMP-1.

3-19

Case 1:91-cv-01362-CFL

Document 195-10

Filed 07/27/2006
Su#aceWaler SW/BMP-2

Page 16 of 37

August .1989

Lack of Flow Measurement C-1 at Pond BMP A Ptowmeter at outfall of C-1 Pondwasinoperative when observedon June28, 1989. It is not an NPDES Permit requirement to monitor flow at C-1 pond, but RFPhas indicated an intention to measure report flow whenever and water is leaving the C-1 Pond.The sampling crew leader requested repair of the flow meter, but flows continuedfor several days without knowledge the flow being discharged(1-SW-12). of ~l~llc~ble BMPaJ'Id Recommendations

Ftow measurements essential, to completely document are water releases. 1) 2) Until the meter is repaired/replaced, water height measurement should be taken manually give some to estimateof daily flow at the time of sampling. Repair/replacement the meter should be expedited and spare parts should be of kept on handto speedup future repairs. Seerelated Finding SW/AF-6.

3-21

Case 1:91-cv-01362-CFL

Document 195-10

Filed 07/27/2006
Surface Water SWIBMP-3

August 37 Page 17 of 1989

SWIBMP.3

Inadequate Protocolsfor T~mety Identification of Pollutant Releases Sewage to Treatment Plant BMP Finding RFP does not havean adequateprotocol to expedite analysis and confirm the source of an unplannedpollutant release to the sewage treatment plant. For example, the time elapsed fromfirst notice of the greenisheffluents at the sewage treatmentplant on February 1989.until positive identification of the spill as chromium 13 mg/I on 23, at March 1989. Despitethe fact that potassium 1, dichromate listed among initial was the possible constituents on the first day (SW-13), samples werefirst analyzedfor organic compounds and other chemical parameters before analyses for chromium were conducted. Eventhough a weekend intervened, the emergency nature of the release should havebeensufficient causeto expedite analysesand confirm the sourcewithin a shorter time pedod. ~.potlcable BMPand Recommendations

Develop analyticaJ screeningprotocol for rapid turn-aroundof results in the an event of suchemergencies, include qualitative screeningprocedures metals, for organicsand radioactive constituents. 2) Provide for priority handling of samplestaken during emergencies,including coverage on weekends holidays, and

3-23

Case 1:91-cv-01362-CFL

Document 195-10

Filed 07/27/2006
Surface Water SW/BMP-4

SWIBMP-4 Page 18 of 1989 37 August

Cooling Tower Blowdownat Building77~, ~]MP Flndlnq Thecurrent practice-of disposaJof the cooling tower blowdown Building 77~. may at result in contaminants migrating into the groundwater. cooling tower on the roof of A Building 774. (MadeyIso-Temp)discharges its blowdown the courtyard between to Building 774 and the detachedRoom immediatelywest of the I~uilding. While 309 this practice is not specifically prohibited, the discharge results in a pool of standing waterin the courtyard. Eventuallythis waterpercolatesinto the ground,carrying with it any contaminants which maybe present in the blowdown. A~ollcable BMP and Recommendqtl0r~

Provide a connection from the Building 774 cooling tower blowdcwn conveythat to flow to the sewer collection system trestment. for

3-25

Case 1:91-cv-01362-CFL

Document 195-10

Filed 07/27/2006
Surface W~ter SW/8~P-5

Page 19 of 37

~P Ffndlnq

Tltfe

Dam Inspection Reports

No clarification was sought on the inconsistency in the hazard potential rating assigned to DamC~ in the report prepared by the Corps of Engineers (COE). The annual report prepared by the COE'scovering their inspection of all 12 damsat RFP continually lists Dam C-2 as having a "Significant HazardPotential". even though the text of the reports and the summary deficiencies never provide a rationale for such of listing. Individual COE inspection forms show that C-2 has "LOW Hazard Potential" with respect to structure] integrity and genere~ safety. In an effort to resolve this apparent anomaly, the DOE Audit Teamcontacted a COE inspector (I-SW-23). The "Significant Hazard Potential" rating for [:)am C-2 has relationship to the dam's structural integrity, safety, or general characteristics: it reflects the proximity of the downstream community. ~pollcable BMP and Recommendations

In order to avoid confusion regarding COE'srating for DamC-2, RFPshould request written clarification of the rating in the next annual inspection report, due within the next month. Otherwise, the public or news media mayincorrectly infer that DamC-2 is in imminent danger of collapse.

3-27

Case 1:91-cv-01362-CFL
Audit Dlsclollne ~P Flndln¢l,

Document 195-10
Surface Water

Filed 07/27/2006

Page SW/BMP-S 20 of 37 August 1989

Number SW/BMP-6 Laundry Operations

BMP Flndtnd TItlff ~l~P FIndlna

The current large volumeof wastewater from washinguncontaminated slightly or contaminated laundry being directed to Building 374 evaporator may be unnecessary. Theconcentrationof activity in the wastewater maybe low enough the water to for be dischargedto the sanitary sewersystem.Thepractice of directing the water to the Building 374. evaporator is a carryover whenboth low-level contaminated laundry and highly contaminated laundry werewashed the same in facility. A~llcabte BMP and Recommendations

A newlaundry for uncontaminated/low-contamination items is scheduledt0 go online [n the fall or winter of 1989. This facility will be detached from the process buildings in a separate structure. TheRFPshould investigate makinguse of this segregation to reduce water usage and westewater volumesand consequently the load on the Building 374. evaporator.Possibleactions include: Use of a cascaderinsing systemwherefinal rinses are re-used to make up washsolutions. Use of Equipment designed to use lower flow rates/volumes of wash-water and rinse-water. Further separation articles by radiclogicai surveysin an attemptto havethe of least contaminated articles yield wastewaters which do not have to be evaporated treated as a radwaste,end whichcould be released directly to or the sanitary drain.

3-29

Case 1:91-cv-01362-CFL
Audit Dleclollne ALtdlt

Document 195-10

Filed 07/27/2006
Surface Water SW/NP-1

Page 21 of 37 ,~ugust198g

Findlno Number

Audit Findlno Title Noteworthy Practice

Utilities Operations Building371/374. at Complex

Building utilities mamagement operators at Building 371/374complexhave made and extensive use of effective computertechniques to monitor all aspects of utilities operations, Water flows can be adjusted automatically or manuallyat the touch of a button. Alarm systems give immediate warning of unusual conditions. Sensors located at the floor of pump roomsmonitor for moisture indicating a leak. Routine maintenance schedules are computerizedto remind operators whento do preventive maintenance. E~tensiverecords of operating conditions are maintainedin a ready for use mode,and mylar copies of all drawings are modified to always be showingthe current layout of the utility lines. Operatorswereable to answer all questionsabout their systems and provide these answers without delay or confusion, indicating a high level of training andattentionto detail. Thereis an ongoingprogramat RFP incorporate such practices at other utilities to operations, but formal written procedureshave not yet beenfinalized. Efforts to completethese tasks in a timely fashion should be encouraged, not only at RFP,but also at other DOE facilities.

3o31

Case 1:91-cv-01362-CFL

Document 195-10

Filed 07/27/2006

Page 22 of 37

Case 1:91-cv-01362-CFL

Document 195-10
4.0

Filed 07/27/2006

PageAugust 37 23 of 1989

GROUNDWATER

- GROUNDWATER

SCOPE OF AUDIT Review hydrogeologicsetting and physical conditions Review current monitoringsystemfor the following items a. Well construction design and as-built details b. Well locations, numbers,and depths, etc. c. Samplingprocedure and chain-of-custody observations

Review Remedial Investigation and Feasibility Studyandreports for: a. High priodty sites b. Intermediate Pricdty sites c. Low pdority sites RCRA Post Closure Permit Application for Current Landfill, Solar Evaporation Ponds,WestSprayField, andold ProcessWaste Lines relative to: a. b. Conformance consentorder and "approved"closure plans, etc. to Rationale of plans

Reviewgroundwaterand soil monitoring, record handling and data reporting to regulatory agencies Evaluate groundwater pathways, BackgroundGeochemicalInvestigation Plan, and Geophysical Study Plans

4-1

Case 1:91-cv-01362-CFL

Document 195-10

Filed 07/27/2006

GROUNDWATER Page 24 of 37 August lg8S

GROUNDWATER FINDINGS

AUDIT FINDINGS: GW/AF*I GW/AF-2 Uncharacterized ~xtent of Soil ~nd Groundwater Contamina~on Inactive WasteSites at - lack of AdequateUpgr~dient I~ackgroundMonitoring Wetls

BEAST MANAC3.~MENT PRACTICI~S: GW/I~MP-1 GW/BMP-2 GW/BMP-3 GW/BMP-4 GW/BMP-5 Use of Groundwater Monitoring Wells of Unknown Construction lack of Comprehensive Organized GroundwaterData Database Deficiencies in Groundwater SamplingProcedures Lackof Adequate Quality Assurance/Quality Control of WorkProducts Deficienciesin Well Filter Construction

NOTE~WORTHY FRA~TI(~E$: GW/NP-1 Implementationof the Use of Advanced Geophysics

4-3

Case 1:91-cv-01362-CFL
~gdlt Dlscl~llne

Document 195-10

Filed 07/27/2006
Groundwater GW/AF-1

PageAugust 37 25GW/AF.1 of 1989

_Audit Ftndlno Number AIJdlt Find[no Title

Uncharacterized Extent of Soil and Groundwater Contamination Inactive at WasteSites

,~gdlt Ftndlna and Ao~llcable Thehorizontal and vertical extent of soil and groundwater contaminationhas not been completely characterized at known suspectedinactive wastesites. The RockyFiats ~nd Plant (RFP)has subdivided the areas of suspectedcontaminationinto groups of three priorities for investigation and remediation. At the time of the audit, none of the investigations had beencompleted.In addition, the current investigation plans do not appearto include provisions for the completecharacterization of the horizontal and vertical extent of contamination.Progressmade the time of the audit and examples at of deficiencies are as follows: High Priority Sites: 881 Hillside Area: Soil contamination source terms are not well enoughdefined horizontally and vertically to permit an adequate assessment the volume of and area Of contamination if the need for removal, as a remedial action, becomes warranted. A "Final Draft" Remedial Investigation (GW-1),Environmental Assessment (IWS-13), and Feasibility Study (IWS-9) have been performed. An interim RemedialAction is also planned(GW-65). However, the time of the Audit, there wereno wells north of three at Solid WasteManagement Units (SWMUs), (119.1, 119.2, and 130) to characterize horizontal and vertical extent of contamination those areas. Analysis of samples in from wells in and near the areas of these SWMUs indicate contamination exists in the groundwater and/or soil from semi-volatiles, volatile organic compounds, possibly and metals. Analysis of samples from wells located downgredient of these areas have indicated no contaminants havemigratedto them. MediumPriority Sites:

903 Pad, Mound,and East Trenches Areas: The horizontal and vertical extent of contamination wasnot completelydefined during the initial phases the investigation of (GW-19 and GW-22). A "Draft" Remedial Investigation (GW-19 and GW-22), SamplingPlan for PhaseII (GW-20)have been completed. Currently available data indicates soil contamination from semi-volatiles, acetone, and plutonium and groundwatercontamination from volatile organic compounds. The SamplingPlan for PhaseI1 (GW-20)appears to adequately describe the work necessary to define the extent of contamination.However, plan has not beenfully implemented. the Low Priority Sites:

Several low priority sites havebeenidentified, but havenot beeninvestigated (GW-42). This groupof sites includes such areas as the A, E, and C Ponds.inactive landfill, ash pits, end numerous small spill areas. Concern raised by the Audit Team during review of the initial samplingplans are that the field investigations are not intensive enough in areas of known sourceterms to detect all areas of contaminationand provide adequate

4De

Case 1:91-cv-01362-CFL

Document 195-10

Filed 07/27/2006

Page 26 of 37

information for planningof fallow-on investigations. Examples insufficiently detailed of sample plans incJude:

1) 2) 3) 4)

All the plans do not provide the rationales for only samplingthe groundwater in the aliuvium. Thesample plan for C Pondsdoesnot explain whyno newwell is being installed in the area. The sample~]an for the GroupO wells does not indicate whether wells to be installed are for alluvial or bedrock groundwater sampling. The sampleplan for B Pondsindicates that only three newalluvial wells are being installed and doesnot explain whyno bedrockbodngor wells are planned. Both the sedimentsand water in these pondsare known be contaminated. to

Referto related finding, IWS/AF-5, additionaJdiscussion theseareas. for of ~potlc~ble Cltetlorl and Reou!rements

Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA (GW-66)require the vertical and horizontal extent of contamination characterized. Re¢ommendat on~

1)

Provide additional borings and wells in order to completely characteri~.e the source(s) and extent of contamination the 881 Hillside Area. Particular areas in include north of SWMUs 119.1, 119.2, and 130. The Interim RemedialAction should be adequate intercept the known to contaminationshould it migrate from the area in a downgradient direction. Expedite the remedial investigation efforts in the 903 Pad, Mound.and East Trenches Areasandprovide additional investigations as needed clarify extent to of contaminated areas. Re-evaluate the LowPriority Sites Sample Plans to ensure that the planned investigation activities adequatelyaddresses potential contaminationin these areas as required by CERCLA. related Finding IWS/AF-5. See

2) 3)

4-6

GW/AF-~

Case 1:91-cv-01362-CFL
Audit Dtsclollne

Document 195-10

Filed 07/27/2006
Groundwater GW/AF-2

August 1989 Page 27 of 37

Audit Flndlno Number Audlt Findlna Title A~lcllt F~ndlna and Ao~!Iceble Reference

Lack of AdequateUpgradient Background Monitoring Welle

There are no grou~dwater monitoring wells upgradient of Solid Waste Management Units (SWMUs) 119.1, 119.2, and 130, that can provide either background data relative the those SWMUs define the upgradient extent of contamination. See related F~nding or GW/AF-1. There are presently several SWMUs within the 881 Hillside Area that have apparent groundwater contaminationrelative to constituent levels in the "background" area. west of the plant. Groundwater analyses for wells in the vicinity, anddowngradient, of SWMUs 106, and 107 indicate possible contamination from selenium, strontium 103, and uraniumSWMUs 119.1, 119.2, and 130 maybe contaminatedwith nickel, selenium, strontium, and uranium.Twenty-eightgroundwater monitoring wells have beeninstalled as part of the remedialinvestigation of the 881 Hillside Area. However, only oneshallow alluvial well (1-87) is presently capable of providing SWMU specific upgradient groundwater background data near SWMUe 106, and 107. The 881 Hillside Area 103, RemedialInvestigation report has failed to adequately explain the elevated metal concentrations (GW-12)relative to distant backgroundwells. It does not provide adequatenumbers locations of nearby background and wells to substantiate the claim that these values are due to a different local geochemical environment (GW-1, 5-55). pg. Theability to accurately and confidently discriminate between natural concentrationsof groundwater constituents and man-made impacts is based on the knowledge of background values relative to the specific area of suspectedcontamination. Upgradient background groundwatermonitoring wells located near these areas are neededfor such a comparison.However,such wells have not been installed. In the case of the 881 Hillside Area, the lack of adequateupgradient groundwaterdata has prevented Rocky Flats Plant (RFP) from defining the risks which are associated with the levels that contaminantsare elevated abovebackground levels (i.e., man-made impacts). Current remedial action plans include treatment for metals which are thought to be elevated relative to concentrations of metals found in distant background monitoring wells, but whichmaynot be elevatedrelative to natural occurringlocal conditions. Aoollcable Citation and Reoulremente and Feasibility Studies Under

Guidance for Conducting Remedial Investigations CERCLA, Interim Final (GW-66).

Section 3.2.4.1, ~ provides guidance that upgradient background water quality in an area near the suspectedcontaminantsourceshould be determined. Recommendations RFPshould supplement their existing groundwater monitoring program to provide upgradient background groundwater monitoring wells and soil borings that are located in areas which would allow background conditions to be characterized for eachSWMU, or area of suspected contamination,rather than distant wells or borings that may be not representative the true conditionsat the units. of
4-7

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

Document 195-10

Filed 07/27/2006

Page 28 of 37

Twoareas where additional installed ~re as follows:

upgradient groundwater monitoring wells should be

1)

SWMI.~s 103, 106, and 107 have only one well located to the west the units. Additional wells Should installed to the north of the units, adjacentto B-881. he SWMUs 119.1, 119.2, and 130 do not have any local upgradient wells. These a~'easshouldha.vewells installed in the hillside area. north of eachSWMU.

RFP currently in -tKe ~rocess installing additional groundwater is of monitoringwells in the g03 Pad, Mound,and East TrenchesAreas (GW-19)and RCRA interim monitoring areas (GW-47). The Low Pdodty Sites RemedialInvestigations Plan (GW-42)had beenimplemented the time of the AudiL Since these projects werein the eadystage at of completion,they havebeenexcludedfrom this finding~ Refer to Finding GW/AF-1 a for discussionof thoseprojects.

Case 1:91-cv-01362-CFL
Audit 01sciollne

Document 195-10

Filed 07/27/2006

Page 29 of 37

Groundwater

Useof Groundwater Monitoring Wells of Unknown Construction

Groundwater monito~.ing wells (approximately 56) of unknown construction have been installed in several areas of the site since the late 1960's and prior to the current Environmental RestorationWell Installation Program (IWS-1). Thesewells are ourrer~tly being used in the groundwater monitoring program.No information exists as to the built construction. It is unclear whether these wells can produce representatfve groundwatersamples. Problemscan oocur from improperly constructed wells such as: 1) allowing surface water to enter the sampling zonethrough infiltration along an unsealedcuing, 2) allowing mixing of groundwater from different water bearfng zones, thus either crosa-oontaminating zonesor diluting constituent concentrations from morecontaminated zoneswith less contaminated water, and 3) improperly selected well construction materials mayinterfere with groundwaterchemistry through leaching or absorption of contaminants concern. of During samplingof well 10-81, the Audit Team observed that the well wasnot locked, did not havea protective outer casing, and did not havea concretepad at the surface. The casing was in a depression approximately three inches deeper than the surrounding area, allowing purge water to flow back into the well head. Since there is no as-built recordof the construction this andother wells, it is not known the casingis sealedin of if the borehole to prevent surface water from flowing downalong the well casing and enterfng the groundwater samplingzone. Well 10-81is within approximately fifty feet of well 7-82 whichis of similar construction, and doesnot yield enough water to allow a complete of sample set containersto be filled fromit. These older wells (10-81and7-82) have been replaced with two newwells (48-86 and 49-86) which were constructed in accordancewith RCRA construction guidelines and installed approximately 250 feet away.This is an acceptabledistance since they Ee background wells. TheRocky Flats P!ant (RFP)currently uses older wells for groundwater monitoring even though replacement monitoring wells of knownand documented quality have been installed to replace them. Analytical data and inferences drawnfrom the older wells is consideredin some the RI/FS process (GW-1, of GW-18, GW-22). is possible that and It errant inferences and subsequent planning and decisions maybe drawnas a result of useof the analytical data drawn fromthese wells. Aoollc~]ble BMPand Recommendation~

Groundwater monitoring wells of unknown construction should be properly abandoned (RCRA, Technical Enforcement Guidance Document, Section 3.7). RFPshould commence activity as soonas practical. Although is a low pdority item relative to this it other Environmental Restorationprogram activities, it is a simpleprocessthat doesnot require intensive efforts in sampling, data reduction, or evaluation. A report of each abandonment, including observationsof as-built construction, should be produced. Unused wells, piezometers, or soil borings should be abandoned over-drilling the by existing casing to remove then grouting the boring with a nonshrinkgrout mixture it,

Case 1:91-cv-01362-CFL Auguzt 1989

GW/BMFol

Document 195-10

Filed 07/27/2006

Page 30 of 37

(using a tremie pipe), starting fromthe bottom the hole andpumping of grout untii reaches surface. the (Blank)

4-10

Case 1:91-cv-01362-CFL
Audit Discipline

Document 195-10

Filed 07/27/2006

Page August 37 31 of 1989

GW;BMpo2

Groundwater/Best Management Prac:ices Plan GW/BMI=.2 Lack of Comprehensive Organized GroundwaterData Database

BMP PlndlncLNumber BMP Flndlr~e Title

Analytical data producedby the 881 Quality Laboratory, and two offsite contract analytical laboratories in conjunction with the Environmental Restoration Program are not organized an efficient and useful manner. in RCFIA facility interim status monitoring (GW-46) data reported to the state on March1, 1989for the precedingcalendar year incomplete some the wells andnot sorted by well identification number. for of Statistical calculations are not performedto evaluate potential contaminant releases. Other site areas being monitored, such as the backgroundareas, 881 Hillside Area. 903 Pad, Mound, East TrenchesAreas, are not reported and an organizeddata table for all and areas wasnot available. RFP currently in the processof entering into a database restructuring previous is and groundwater data reported from the laboratories usedin the remedialinvestigations, and RCFIA ClosureProgram (I-GW-25).Thedatabase program,written by a contractor for the site Environmental Restoration Program, presently configuredis specifically odented as to pro-selected well groupsand one reporting format. At present, there is no in-house capability Io selectively manipulate sorting andreporting formats, andthe data input the processrequires certain data fields to be sorted in sequence. project is incomplete, The and the database systemis not capableof directly interfacing with the 881 Laboratory systems. Applicable BMPand Fle¢ommendattons

Thequantity of analytical data generatedthrough the remedial investigation and RCFtA Closure Process needs to be managed an orderly mannerfor easy reference and in evaluation (RCFIATechnical EnforcementGuidanceDocument,pg. 171). Data should be maintainedthrough databasesystemsthat permit selection and sorting of several parameters such as the contaminant,well identifier, date of sample,values greater or less than detection limits, contaminant concentration,data qualifiers, etc. Datalistings should be available in an organized, tabulated output relative to eachof the specific SWMUs OperableUnits and sorted by well or contaminant. or The use of computerized databases also allows efficient and rapid evaluation of analytical data for detection and assessment contamination of migration from hazardous waste management facilities (FICFIA Technical EnforcementGuidanceDocument,pg. t 70). There are numerous computerdata management packagesavailable that are easy to use and can be specifically addressed the needsof the Environmental for Flestoration Program. Theusers and suppliers af analytical groundwater monitoring data (as well as soil and sedimentdata) should install a database system,and incorporate current and valid analytical data from all of the site programs one central, mutually accessible, in systemthat canbe usedby the laborato~/, consultants, andprogram personnel.

4-11

Case 1:91-cv-01362-CFL

Document 195-10

Filed 07/27/2006
Groundwater

Page 32GW,'B of 37MP.3
August 1989

BMP FtndlnQ

Number

GW/~MF-3 Deficiencies in Groundwater Sampling Procedures

BMPFlndtna Groundwater sampling procedures (GW-61)used by the 881 Laboratory sampling team include practices that do not follow recommended regulatory guidance or standard industry practices. Those practices observed include the following:

1)

Indicator parameters(pH, temperature, specific conductivity, and dissolved oxygen)are not monitoredbefore or during the processof purging to ensurethat all stagnant water has beenremoved from the well casing and that the sample beingtakenis representative the in situ waterquality. of The samplerswere not awareof the formal written Chain-of-Custodyprocedure (I-GW-17and I-GW-21). They had been verbally instructed in the procedures. The chain-of-custody was broken when the samples were delivered to the laboratory. Prior to the transfer of custody, a laboratory technician wasobserved performinga pHcheckon the preservedsolutions in the samples.Thetechnician wasnot authorized to take receipt of the samples.Seerelated Finding SW/AF-4. Another lab .3erson, authorized to receive samples,had to be located for the custodytransfer; transfer took place after the technicianchecked pH. the Noformal training program refresher training is providedto the groundwater or samplingteam(I-GW-17and I-GW-24)by their supervisor or division to ensure that the samplers understand procedures performthemcorrectly. the and Equipment procurement,assembly,or repairs maytake monthsto be completed. Delays in obtaining equipment repairs have caused quarterly scheduled or required samplingto be missed(I-GW-17).A trailer, procuredto carry equipment used for purging deeperwells has experienceddelays in assembly (I-GW-17). A samplertouchedthe retainer ball in the bailer with his finger in order to pour sample water from the bottomof the bailer into the VOA vials therebypotentially introducing contaminants into the sample. Other opportunities for sample contamination inctude: 1) storageandsubsequent reuseof bailers with only field decontamination rather than a morethoroughlaboratory decontamination; 2) overnightstorageof bailers following purgingof a well anduseof that bailer to collect samplesfrom the well without prior decontamination; and 3) contact between bailer and the protective steel casing during sampling; this occurs the becausethe top of the inner well-casing is greater than 7 inches below the protective casing, as originally designed,and the bailer mayswingfreely during sampling.

2)

3) 4)

~llcebte

BMP and Recomm~n~tion~

Thesamplingproceduresshould be emended be consistent with regulatory guidance. to The following recommendations should be implemented:

Case 1:91-cv-01362-CFL GW/BM~.3
August 1989

Document 195-10

Filed 07/27/2006

Page 33 of 37

Theeffectivenessof well purgingshouldbe evaluated that anyirregularities in so analytical results cannot be suspectedas having beencausedby stagnant water in the wetL Although pH, specific conductivity and temperatureare monitored four times during sampling for all non-VOA analytes, RCRA guidance (RCRA Technical Enforcement GuidanceDocument) to monitor these indicators plus is dissolved oxygendudngpurging. Theinitial version of the proceduresrequired this practice (t-GW-26), but monitoring during purging was removed from the subsequent version of the procedures (I-GW-26). Purge monitoring is not currently in the procedures (GW-61).

2)

The Chain-of-Custody description in the sampling procedures should be expanded more fully document to the process. In addition, current written procedures explaining the use of the form, and individual responsibility needto be updatedto include sampletracking in the L~oratory. Procedures should be establishedwhichallow for immediate transfer of custodyfrom the field sampting teamto the analytical team upon samplereceipt at the Laboratory. Laborato~ personnel should not workwith the samples until custodyhas beentransferred. Thesamplingteam, andtheir alternates, should be providedwith formal training that includes such items as wdtten proceduresfamiliarization, field methods, documentation requirements, and equipment use instruction. Periodic refresher coursesthat include updatesand changes methods in should also be conducted. Procurementof supplies and equipment, repair of damaged malfunctioning or equipment, and assembly of new equipment should be dealt with in a more expeditious manner. Samplingprocedures and equipment, such as closed-top Teflon bailers, for collection of samples be analyzedfor volatile organicsshould be developed to to eliminate sampler contact with water and equipment surfaces. Procedures should also require morethoroughdecontamination bailers, and wells should of be modifiedto minimize contact with the steel casings.

4-14

Case 1:91-cv-01362-CFL
Audit Dfsclollne

Document 195-10

Filed 07/27/2006
Groundwater

Page 34 of 37

BMPFtn~In~

Number

GWIBMP~4 Lack of AdequateQAJQC Work of Products

BMP Findtn~ TI|I~

Work products associated with the CEARP process and CERCLA program remedial investigations have had errors in the construction of geologic cross-sections and graphical representation of geologic logs. Analytical data and boring logs havebeen omitted from appendices. Manyof these deficiencies have been noted in document review comments from regulatory agencies (GW-6and GW-12),and the DOE (GW-8). Examples quality problems of observed the Audit Team listed below. This is not a by are comprehensive of all quality problems list observed presentin the documents, it is or and ~reeentedonly for the purposeof providing examples.Theseexampleswere observed dudnga review of the Remedial Investigation Report for the 903 Pad, Mound, and East TrenchesAreas (GW-19 GW-22).Problemsobservedare as follows: and 1) A geologic cross section on Plate 5-8 hasthe east andwest directions reversed. Plate 5-4 showscross sections E-E' and F-F' that cross east of BH36-87 and southeast of well 20-87BR.The sections are not consistent relative to the subsurface materials shown. Section F-F' showsa sandstonelayer to extend below borings 8H35-87and 8H36-87and continue to the east past the point wherethe two sections cross. Section E-E' showsonly claystone betweenwell 20-87BR and 18-87BR the area wherethe two sections cross, not sandstone in as shown the other cross section. in Oncross section E-E' and G-G', the graphic log of well 18-87BR plotted is differently. Likewise, well 23-878R shown two different cross sections with is in different screened depths. Thetext on pages5-8 and 5-9 discussescorrelations between these two borings. It is unclear from the cross sections what the Irue subsurface conditions are, and it is also unclear how a correct technical conclusioncould be drawnfrom these conflicting inferences. Onpage 5-20, well 20-87BR was reported to have no data available, and a conciualonwasmade that bedrockcontaminationdid not exist. However. data for one quarter is listed in the data appendix as sample 20-87-10-26-87 and indicates low level (single digit ppb level) of Volatile OrganicCompounds (VOCs) werepresent. Furthermore, well 1-74 (an older well of unknown construction) located adjacent to well 20-87, showscontaminationof VOCs. is unclear how It the conclusionthat there wasno contamination that area wasarrived at. and in whya technical reviewdid not detect this discrepancy. Thecausefor these problems unclear, but the aggressiveschedulein the July is 1986 ComplianceAgreement that did not allow adequatetime for thoughtful reviews is suspectedby the Audit Team a principal contributor. Adequate as reviews are now incorporated in the report process by someof the site environmental program contractors (GW-60), scheduled specific activities and as in the draft Five YearPlan(I-GW-15).

2)

3)

4)

GW/BMP-4 Case 1:91-cv-01362-CFL August 1989

Document 195-10

Filed 07/27/2006

Page 35 of 37

A~J~l~cable

BMPand Recommendations

Currentindustry practice requires in-housepeer reviewof workproductsprior to release or transmittal to clients, including draft work products. Theexisting E]aaic Qrdering Agreement(BOA) in use by RFPincludes a clause in the General Provisions that requires the contractor to performaccordingto indust~ standards. Nospecific language exists in either the BOA the TaskStatements Work(SOW) or of that require a QAIQC program. Although RFPhas contracted for field oversight and independent technical review, there should also be requirementsin the contract that incorporate in-house peer review. Contract requirements should be incorporated into each SOW requiring that QNQC plans be developedthat are relative to the specific items within the SOW. The QNQC plans should be reviewed by the site along with the technical proposal for adequacy completeness. and Items included in the peer review should not be confused with laboratory QAfor analytical work, but should deal with issues suchas checkingthe accuracyof drawings, calculations, appropriatetechnical conclusions,support, andbasis in fact, completeness of appendices,and transcription of data from bcdnglogs, field tests, and laboratory analyses.

4-16

Case 1:91-cv-01362-CFL

Document 195-10

Filed 07/27/2006
Groundwater GW/BMP-5

GW/eMP-~ Page 36 of 37

BMPFlndlno ~tle 18MPFtndlnq

Deficiencies Well Filter in Construction

The groundwatermonitoring wells have been constructed using a single sized filter sand (GW-16,and GW-47).In somecases this construction practice has allowed fine particles to enter throughthe well screenandcausethe wells to silt-up (I-GW-21).These wells maynot be capable of providing the sample volumesrequired for groundwater analyses. Environmental Restoration (ER) Program personnel reported that someof the monitoring wells haverequired re-development order to maintain them(I-GW-21). in Ag~ltcsble BMPand Recommendatforts

AJl future monitoring wells should be constructed using a filter sand which has been selected basedon the grain size of the specific formation being monitored. The well screenslot size should then be selected basedon the filter sandsize (RCRA, Technical Enforcement Guidance Document, and CERCLA Compendium.of Field Operations Methods).Because the continuing maintenance of required on the current wells, the site shouldreviewthe well filter sanddesignfor individual wells and determine a case-byon case basis whetheror not they needto be replaced.

Case 1:91-cv-01362-CFL
Audlt OIs~lollne

Document 195-10

Filed 07/27/2006
Groundwater GW/NP-t

Page 37 of 37

Audit F~ndln~ Number Audit F~ndln~ Title Noteworthy l=ractlce

Use of AdvancedGeophysics

All OOE facilities whichare in the processof planning the investigation of actual or potential pathwaysof contaminantmigration should consider using indirect testing methods (i.e., geophysics, soil gasanalysis) in the early stagesof the investigation assure that more expensive techniques such as monitoring well installation and samplingare usedeffectively. The RockyFlats Plant (RFP)has introduced the use High Resolution Geophysical Seismic Reflection methodsto assist in defining sand lenses w{thin the Arapaho Formation.Implementation this processwill save time and of money both the investigation and design phasesof the EnvironmentalRestoration in Programby locating the potential contaminantmigration channels. Sandstone lenses within the Arapaho Formationclaystone and siltstones are the result of depositional processes an ancient fluvial-lacustrine environment. sandlenses occur as buried in The channels fine-grained silty or clayey sandwithin bedded interlayered claystoneand of or siltstone. Thechannelsoccur randomly rangein size from a few feet to several feet and in thickness and hundreds feet in length. Since mostof the areas to be investigated of are beneathfive to forty feet of Pleistocene RockyFlats Alluvium, remotemethods to locate the channelsare required. The process of implementing this methodhas been composed a series of planned of steps: 1) evaluationof the potential cost of conventional drilling investigation techniques versus seismic methods target sandlenses ddlling targets (GW-62), performance to 2) a numerical modelingevaluation to determinethe physical conditions under which the method wouldperform, andif it could be applied successfully at the site (GW-63), and development a work plan to performa field test program evaluate and calibrate the of to testing (GW-64). field program testing has beencompleted, initial screening The for and indicates the method will work successfully. As a result of these operations, a program has beenimplemented use the method the Remedial to in Investigations associated with the 903 Pad, Mound, and East TrenchesAreas. Field production seismic investigations are scheduled commence August1989as part of the remedial investigation process. to in