Ground Water Surveillance Monitoring Implementation Guide for Use with DOE O 450.1, Environmental Protection Program <AUTHOR> James Bachmaier <AUTHOR_EMAIL> James.Bachmaier@eh.doe.gov <AUTHOR_PHONE> (202)586-0341 <ORG> EH <SandH> N <SUMMARY> The purpose of this Guide is to assist DOE sites in establishing and maintaining surveillance monitoring programs to detect future impacts on ground water resources from site operations and to assess potential for exposing the general public to site releases. <DATE_ISSUE> 03/24/2004 <DATE_CLOSE> <DATE_REVIEW> <TEXT> DOE G 450.1-6 DRAFT MARCHXX-XX-2004 Ground Water Surveillance Monitoring Implementation Guide for uUse with DOE O 450.1, Environmental Protection Program [This Guide describes suggested nonmandatory approaches for meeting requirements. Guides are not requirements documents and are not to be construed as requirements in any audit or appraisal for compliance with the parent Policy, Order, Notice, or Manual.] U.S. Department of Energy Washington, D.C. 20585 PREFACE DOE G 450.1-6, Ground Water Surveillance Monitoring Implementation Guide for Use with DOE O 450.1, Environmental Protection ProgramThis Guide is one of a series of Guides issued to provide suggested approaches for meeting the requirements of DOE O 450.1 Environmental Protection Program, dated 1-15-03, which. DOE O 450.1 requires Department of Energy (DOE) elements Organizations to establish an Environmental Management System (EMS) that is integrated intopart of DOE’s Integrated Safety Management System (ISMS). DOE G 450.1-6 This Guide provides a description of the elements of an integrated site-wide ground water surveillance monitoring program that can be adapted to unique physical conditions and programmatic needs at each DOE site to meet the requirements of DOE O 450.1. CONTENTS 1. INTRODUCTION 1 2. DOE REGULATIONS AND ORDER REQUIREMENTS RELATED TO GROUND WATER MONITORING 2 a. 10 CFR, Part 830, Nuclear Safety Management 3 b. DOE O 450.1, Environmental Protection Program 3 c. DOE O 5400.5, Radiation Protection of the Public and the Environment 4 d. DOE O 435.1, Radioactive Waste Management and DOE M 435.1-1, Radioactive Waste Management Manual 4 3. SURVEILLANCE MONITORING 5 a. Objectives for the Design of a Site-wide Surveillance Monitoring Network 5 b. Contingency Plans 7 c. Site-wide Review of Historic and Current Operations and Practices 7 d. Prioritization of Vulnerable Areas of the Site 8 e. Subsurface Characterization and Hydrology 8 4. MONITORING NETWORK DESIGN 9 a. What Constitutes a Monitoring Network 9 b. Basic Understanding of the Flow System 10 c. DQO Process Applied to Network Design 11 (1) State the Problem 11 (2) Identify the Decision 11 (3) Identify the Input to the Decision 12 (4) Define the Boundaries of the Problem 12 (5) Develop a Decision Rule 12 (6) Specify the Tolerable Limits on Decision Errors 13 (7) Optimize the Design for Obtaining Data 13 d. Ground Water Monitoring Plan 13 5. INTEGRATION OF THE GROUND WATER MONITORING NETWORK 14 6. GROUND WATER MONITORING PROGRAM EVALUATION 15 a. Ambient Quality of Ground Water Resource 16 b. Specific Data Needs 16 CONTENTS (continued) c. Scope of Site-Wide Monitoring 16 d. Purpose and Design of Monitoring Network 16 e. Data Management 16 f. Ensuring Efficiency and Cost Effectiveness 16 g. Utility of the Monitoring Data 16 h. Continuous Improvement of Existing Monitoring Programs 16 i. Alternative Monitoring Methods 16 j. Analysis of Trends 17 7. SURVEILLANCE MONITORING PROGRAM FUNDING 17 8. REFERENCES 18 GROUND WATER SURVEILLANCE MONITORING IMPLEMENTATION GUIDANCE 1. INTRODUCTION . The purpose of this guidance is to assist each DOE sites in establishing and maintaining a surveillance monitoring programs to detect future impacts on ground water resources from site operations and to assess potential for exposingure to the general public to site releases. This implementation guidance guidance— * describes the essential elements of a site-wide ground water surveillance monitoring network,. The guidance * distinguishes the objectives of a surveillance network from a network designed to meet specific external regulatory requirements related to restoration,. It * distinguishes short termshort-term monitoring program goals from long termlong-term stewardship monitoring goals, and. It also * addresses the integration of existing ground water monitoring activities into the site-wide monitoring network. In addition to providing real- time environmental measurements for estimating potential human dose, the site-wide ground water surveillance monitoring system must should provide a mechanism for detecting releases to the subsurface environment from a DOE facility or activity that will trigger an appropriate response, to prevent or minimize adverse impacts on ground water resources. The emphasis of this guidance is the creation and maintenance of a site-wide surveillance monitoring program at each DOE site that to serves as the basis for long-term surveillance for environmental stewardship. This document provides guidance (Section II2 of this Guide) addresses for integrating internal and external ground water monitoring requirements contained in the following. * Title various DOE regulations (10 Code of Federal Regulations (CFR), Part 830,) Nuclear Safety Management. and * Orders (Order DOE O 450.1, Environmental Protection Program, dated 11503. Order * DOE O 5400.5, Radiation Protection of the Public and the Environment, dated 17-93. and Order * DOE O 435.1, Radioactive Waste Management), dated 8-28-01. * DOE M 435.1-1, Radioactive Waste Management Manual, dated 6-19-01. * DOE G 435.1-1, Chapter 4, Low-Level Waste Requirements, dated 7-9-99. It This Guide is a companion document to AEnvironmental Regulatory Guide for Radiological Effluent Monitoring and Environmental Surveillance@ (DOE-/EH-0173T, January 1991). Unlike EH0173T, though, this guidance addresses addresses radiological and non-nonradiological ground water monitoring. It does not, however, address the technical aspects of monitoring well construction, sampling or analytical techniques, or innovative technology. Section 3 addresses . It does not address the technical aspects of monitoring well construction, sampling or analytical techniques, or innovative technology. It does address, however, the objectives of a site-wide surveillance monitoring program in the context of internal DOE Order requirements for environmental protection, with emphasis on the maintenance and continual optimization of a network designed to provide surveillance over extended periods of time. . It also addresses It also addresses vadose zone monitoring as an integral component of a ground water surveillance monitoring network.; and Section IV4 discusses the concept of a site-wide monitoring network and the technical basis for its design. Although it is important to design a unique ground water monitoring network that provides information for meeting each specific program objective (i.e., external regulatory requirements, DOE Order requirements, etc.), it is also necessary to integrate the individual networks in such a way that individual monitoring wells can be incorporated into more than one network, as appropriate, to achieve cost efficiencies and to optimize the information provided by each well. This guidance also addresses (Section 5) the integration of DOE Order requirements for surveillance monitoring with requirements of external regulations [(the Resource Conservation and Recovery Act (RCRA), the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), etc.)] for compliance monitoring. Section VI6 discusses the site-wide program and the need for continuingal program evaluation as site conditions change over time, and provides suggested criteria for monitoring program optimization. Section VII7 addresses the need for asensuring adequate funding for the on-going, site-wide program. 2. DOE REGULATIONS AND ORDER REQUIREMENTS RELATED TO GROUND WATER MONITORING . There are specific requirements contained in various DOE Orders that relate to the sitewide ground water surveillance monitoring network. The following discussion cites each specific requirement. Each DOE site mustshould meet these requirements in a manner that is appropriate for the site’s unique conditions. It is important, however, for each DOE site to consider the integration of these requirements in designing and upgrading a surveillance monitoring network that is cost effective. a. 10 CFR PR, Part 830, – Nuclear Safety Management . 10 CFR Part 830 requires that aAll DOE nuclear facilities shouldmust perform work in accordance with a safety basis that ensures adequate protection of workers, the public and the environment. According to DOE’s General Statement of Safety Basis Policy (Appendix A to Subpart B of 10 CFR, Part 830, Subpart B, Appendix A), the safety basis requirements are generally met by a site-wide Integrated Safety Management System (Integrated Safety Management System (ISMS)) that includes programs that adequately protect the environment. A ground water surveillance monitoring program, with appropriately designed networks for each nuclear facility subject to 10 CFR PR Part 830,, is an integral component of the site-wide ISMS, and must should be developed and maintained to asensure compliance with 10 CFR PR Part 830. b. Order DOE O 450.1, – Environmental Protection Program (DOE 2003) . Order DOE O 450.1 (issued dated January 15, 2003)The Order requires that each DOE site implement an Environmental Management System (EMS) as part of the site=‘s Integrated Safety Management SystISMSem. The site-wide The EMS must shouldprovide for the systematic planning, integrated execution, and evaluation of programs that ensure be designed to do the following:public health and environmental protection, pollution prevention and compliance with DOE Directives and applicable laws and statutes. An effective EMS should integrate plans, procedures, and program assessment and corrective actions. (1) Provides for the systematic planning, integrated execution, and evaluation of programs for - (a) public health and environmental protection, (b) pollution prevention (P2), and (c) compliance with applicable environmental protection requirements. (2) Includes policies, procedures, and training to identify activities with significant environmental impacts, to manage, control, and mitigate the impacts of these activities, and to assess performance and implement corrective actions where needed. (3) Includes measurable environmental goals, objectives and targets that are reviewed annually and updated when appropriate. DOE sites are responsible for an EMSs that will ensure the early identification of “Ensure the early identification of, and appropriate response to,adverse environmental impacts associated with from DOE operations, as well as ensure that appropriate responses are taken. and surveillance monitoring.” DOE facilities are responsible for integrating the EMS into the ISMS to: consider, as appropriate, the protection of * surface and ground water, (b) implementation of a watershed approach for protection,(c) implementation of a site-wide approach for ground water protection, * (d) protection of other natural resources including and biota, * (e) protection of site resources from site resources from wildland and operational fires, and fires, and * (f) protection of cultural resources. DOE Ooperations/Ffield/Ssite Ooffice Mmanagers are responsible for implementing Order DOE O 450.1 requirements for— * annual budgetary planning and P2 program implementation and monitoring, by, among other requirements, completing the following: * Ensure environmental monitoring to detect, characterize, and respond to releases from DOE activities,. and Conduct, as appropriate, to * a consistent, validated approach for environmental sampling and analysis. (14) Ensure the analytical work supporting environmental monitoring is implemented using – (a) a consistent system for collecting, assessing, and documenting environmental data of known and documented quality; (a) a validated and consistent approach for sampling and analysis of radionuclide samples to ensure laboratory data meets program-specific needs and requirements within the framework of a performance-based approach for analytical laboratory work; and (a) an integrated sampling approach to avoid duplicative data collection. To achieve a fully integrated, site-wide ground water surveillance monitoring program and to meet the Order DOEDOE O 450.1 requirements noted above, DOE field and site office managers must develop the structure of the site-wide program, determine resource needs, evaluate program performance, and identify benefits to be obtained from an integrated program. Headquarters program office managers must provide consistent overall direction to their field and site office counterparts, and provide consistent funding to support the integrated program. Section V5 discusses program integration in more detail. Section VII7 discusses the need for a consistent source of funding for the integrated program. c. Order DOEDOE O 5400.5, - Radiation Protection of the Public and the Environment (DOE 1993) . Order DOEThe Order 5400.5 sets standards for DOE sites and DOE contractors that manage radioactive materials. It includes statements of DOE. It includes statements of DOE’s radiation protection program objectives. Protecting the Public. It is DOE=s objective to operate its facilities and conduct its activities so that radiation exposures to members of the public are maintained within the limits established in this Order and to control radioactive contamination through the management of real and personal property. It is also a DOE objective that potential exposures to members of the public be as far below the limits as is reasonably achievable (ALARA) and that DOE facilities have the capabilities, consistent with the types of operations conducted, to monitor routine and non-routine releases and to assess doses to members of the public. Protecting the Environment. In addition to providing protection to members of the public, it is DOE=s objective to protect the environment from radioactive contamination to the extent practical. Chapter I of DOE 5400.5 DOE sites must Effluent Monitoring and Environmental Surveillance Demonstration of Compliance. Ddemonstrateion of compliance, through effluent monitoring and surveillance. programs, with DOE O 5400.5 requirements of this Order generally will be based upon calculations that make use of information obtained from monitoring and surveillance programs. The abilities to for protecting the general public and the environment. Monitoring and Surveillance Requirements. The 5400 series of DOE Directives provide requirements for o ensuringe that the effluent monitoring and environmental surveillance programs are of good quality. at all DOE facilities and sites, certain requirements and recommendations are provided in DOE Orders in the 5400 series which deal with radiological effluent monitoring and environmental surveillance.DOE 5400.5, Chapter II, of DOE 5400.5 describes DOE’s policy on providing protecting the public and the environment from radiological releases protection of the public and the environment by setting a DOE Ppublic Ddose Llimit (100 mremmillirems, annual effective dose equivalent). , considering all exposure modes and all sources of radiation. ThisThe Chapter chapter also requires that “Ccompliance with the dose limits of this Order shall be demonstrated by documentation of include an appropriate combination of measurements and calculations to evaluate potential doses and the results of the the results of the evaluations.” The Order provides further direction on the specific monitoring requirements for compliance with the dose limits. Monitoring and Surveillance. General requirements for routine effluent monitoring are part of the environmental monitoring plan prescribed in DOE 5400.1. Specific requirements for radiological effluent monitoring and environmental surveillance and their schedule of implementation are prescribed in DOE Orders in the 5400 series, which deal with radiological monitoring and environmental surveillance. The monitoring requirements are applicable to all DOE and DOE contractor operations that are subject to the standards and requirements of this Order. Order DOE 5400.5 refers to the eEnvironmental monitoring programs developed to comply with Order DOEDOE O 5400.1 (General Environmental Protection Program) developed to comply with DOE 5400.1 should continue to be implemented, and should be revised, where appropriate, based on this guidance.. The recommendations contained in this guidance should be used to upgrade the site-wide monitoring programs to ensure that DOE O 5400.5 requirements continue to be met in an the effective and efficient manner. A fully integrated site-wide monitoring program should provide sufficient information on releases to the subsurface to allow estimates of radiological dose to demonstrate compliance with the DOE 5400.5 dose limits. d. Order DOEDOE O 435.1, - Radioactive Waste Management (DOE 2001)and DOE M 435.1-1, Radioactive Waste Management Manual . Order DOEDOE O 435.1 and DOE M 435.1-1 435.1 and DOE M 435.1-1 (DOE 2001a - Radioactive Waste Management Manual) contain specific requirements for management of radioactive waste, pursuant to DOE’s statutory authority (the Atomic Energy Act and related legislation). The purpose of DOE M 435.1-1 is to “...The Manual catalog thosedefines procedural requirements and existing practices that ensure that all DOE elements for DOE organizations and contractors continue to manage DOEs radioactive waste in a manner that is protectiveto protect of workers, the general and public, and safety, and the environment. ” Chapter I of DOE M M 435.1-1 identifies requirements for all DOE radioactive waste management facilities, as applicable, to include “eEnvironmental moMonitoring. at Rradioactive waste management facilities, operations, and activities that comply with DOE 5400.1 and DOE 5400.5. sh DOE M 435.1-1 contains additional monitoring requirements for all waste facilities (high level, transuranic, and low-level) to assure ensure that passive and active control systems have not failed. Additionally, DOE M 435.1-1The Manual also requires that low-level radioactive waste disposal facilities implement an environmental monitoring programs designed to “... include measureing and evaluateing releases, migration of radionuclides, disposal unit subsidence, and changes in disposal site/facility and disposal site parameters that could affect long term performance. which may affect long term performance.” Although DOE M 435.1-1 requires monitoring that complies with other DOE Order requirements in the 5400 series, the guidance for specific types of radioactive waste management units that accompanies DOE 435.1-1 (e.g., DOE G 435.1-1 for Low-Level Radioactive Waste Management – DOE 1999) includes additional requirements guidance for long termlong-term disposal facility performance monitoring, including measuring to detect releases to the subsurface environment. 3. SURVEILLANCE MONITORING . “An EMS must include policies, procedures, and training to identify activities with significant environmental impacts” a. Objectives for the Design of a Site-wide Surveillance Monitoring Network . Surveillance monitoring is performed to detect, at the earliest possible time, any impact on ground water from an operating facility or practice at a DOE site. A surveillance monitoring network should include observation points located and sampled appropriately, based on prioritized areas of the site where the ground water may be particularly vulnerable to contamination. At many DOE sites, observation points are appropriately located in the unsaturated zone, since the occurrence of ground water that may be vulnerable to contamination from DOE activities is well below the surface (i.e., 100s hundreds of feet below ground surface or more). Early Ddetection of a release to the subsurface at the earliest possible time may necessitate vadose zone monitoring to detect releases before the ground water is affected. It is important to understand that the oObjectives of surveillance monitoring are likely to include,, but will be broader than,, the objectives of a monitoring network designed to control and remediate existing ground water contamination. Where active remediation is being implemented, pursuant to a CERCLA compliance agreement or a RCRA corrective action order, monitoring is performed to identify the dimensions of the contaminated area, to measure contaminant migration and changes ing contaminant concentrations over time, and to evaluate the effectiveness of the remedial action. Surveillance monitoring also mustshould also address areas of the site that are not already subject to external ground water monitoring requirements. Surveillance monitoring is performed to determine whether the ground water is being affected by any other site-wide operations that involve management of wastes or other materials that are a potential future source of contamination. The broader, longer -term objective of surveillance monitoring is to provide an early warning to trigger some appropriate response, if to unplanned releases to the subsurface should occur. As such, a surveillance monitoring network is designed to anticipate what could happen that may trigger a response according to the Ccontingency Pplan discussed below. The site-wide ground water surveillance monitoring network should be designed to meet specific short-term and long-term program objectives, which could be short term or long term. Short termShort-term objectives would typically consider active site-wide operations and facilities that are not already subject to external environmental protection requirements. Some examples of these facilities and activities include: * radioactive material storage areas; * research or production reactors; * underground and above ground liquid storage facilities and associated piping; * irrigation systems; * sanitary sewer systems; * industrial wastewater treatment systems; * vehicle repair and maintenance systems; * improperly constructed wells; * past practice waste management sites, including former soil column discharge sites; * abandoned wells; * surplus or decommissioned buildings; and * new construction sites. After considering the materials managed at each site and the vulnerability to contamination of ground water resources in the area, Ssurveillance monitoring networks should be designed, where appropriate, to detect the possibleany future releases to the subsurface from these and other such facilities and activities, after considering the materials managed at each site and the vulnerability to contamination of ground water resources in the area. Additionally, a site-wide ground water surveillance monitoring network should be designed to meet longer -term objectives, primarily for areas of the site where wastes and other subsurface contaminants will remain after all active site operations have ceased. These long long-term objectives, which may fall into the category of environmental stewardship, address closed waste disposal units and contaminated areas of the subsurface where active remediation has ceased. In such circumstances, physical containment measures and control systems , as well asand institutional access controls, have been established to provide primary long termlong-term care. Surveillance monitoring should be considered as a secondary or back-up control system. Its with the primary objective should be toof detecting a releases, should it occur, following from a failure of the primary controls. The ground water surveillance monitoring network should be reviewed periodically and revised as necessary. As time passes, conditions change and the efficiency of the monitoring network needs to be continuously re-evaluated. It is possible that certain facilities or practices that had been considered high priority areas for potential future releases to the subsurface no longer present any significant threat to the ground water resources. This could occur if a practice ceased (e.g., a material storage area has been moved), an active facility is no longer in operation, or hazardous or radioactive materials are no longer managed thereat the site. It is also necessary to periodically revise the sampling plan for the surveillance monitoring network to reflect changing conditions at the site. As historical data is gathered and analyzed, frequency of sampling and types of analyses performed may be re-evaluated and modified to provide more useful information. Optimization software is available to allow program managers to statistically determine the value of data provided by the monitoring network, and to propose modifications, where appropriate. b. Contingency Plans . A carefully prepared contingency plan is a critical element in a site-wide ground water surveillance monitoring network. Fundamentally, the contingency contingency plan identifies ranges of action levels and corresponding responses to be taken if there is positive detection of contaminants are detected or indicators in the surveillance monitoring network. The contingency plan should includedefine an appropriate actions or responses to detection of all positive detections, which could be a confirmed level of a contaminant releases associated with the a facility or practice that is the object of the surveillance monitoring network, or any positive detection of a contaminant that is unexpected or requires some investigation to determine the source of the contaminant. Appropriate actions or responses could range from a simple matter of comparison comparing monitoring results against a regulatory standard or a risk assessment guideline, to re-sampling more frequently in the future, to reporting the detection level to external regulators, to conducting a site investigation to determine the source and need for corrective action. The contingency plan also should also provide guidance on lines of authority and responsibility for invoking contingencies and for reporting and evaluating their results. The data quality objectives (DQO) process, described in Section IV4, should be followed in the development and revision of a site-wide contingency plan, as well as and in the design of a site-wide monitoring network. c. Site-wide Review of Historic and Current Operations and Practices . Each site should institutionalize a process for performing a periodic site-wide review of historic and current operations and practices that may have impacted affected ground water, or current practices that could have impact in the future. The site-wide review should be conducted to provide input to periodic re-evaluation and revision of the surveillance monitoring network. Although most DOE sites have performed site characterizations in the past to determine the extent of existing contamination, and therefore, the size and scope of the remedial actions needed, there is a need to periodically re-visit areas of the site that may not have been included in on-going remedial actions, but may have experienced impacts from current site-wide operations, or may be vulnerable to future contamination, as a resulting from of new site operations. at the site. The site-wide review of historic and current operations should be conducted at a frequency and at a scale that is appropriate for the site=‘s history and current or future mission. Such a review will have additional benefits, in that for new technical staff, who replace former staff, who will not have had the advantage of institutional memory, will have the in providing an opportunity to identify past practices that may be having an impact on the ground water that had not previously occurred or been detected. d. Prioritization of Vulnerable Areas of the Site . There should be a process for assigning priority to site areas of the site where ground water may be vulnerable to contamination and may, therefore, need to be included in the surveillance monitoring network. Such prioritization should be used to formulate future budget requests. Since budgetary and other constraints are always a limitation on the size and scope of the monitoring program, a system is needed to for prioritizeing potentially vulnerable areas of the site is needed. Whenever a review of site-wide historic and current operations and practices is performed, or whenever new activities, new construction, or new missions for existing facilities are initiated, there is a need to determine the vulnerability of local ground water resources, and to re-evaluate priorities for the current surveillance monitoring network. e. Subsurface Characterization and Hydrology . The bThe basic hydrogeologic conditions of the sitegic conditions of the site mustshould be identified and quantified to the extent possible to construct an adequate ground water surveillance monitoring network. Most DOE sites have extensive historical knowledge of subsurface geologic and hydrologic conditions and water quality monitoring results. It is important that this information be assessed consistently when designing or modifying a site-wide surveillance monitoring network. Frequently, models are employed to evaluate ground water conditions at a local area (a waste management unit or an area where active ground water remediation is being performed) or for a short-term purpose (e.g., for plume identification as part of a CERCLA remedial investigation). In designing a site-wide monitoring system, it is important to construct a site-wide conceptual model of the subsurface. This conceptual model should be based on observed data from previous subsurface investigations, and it should also be the basis for future characterization. It is important to perform a site-wide water balance to ensure that occurrence the occurrence and movement of water onto and away from the site, as well as and flow conditions within the site, are accounted for, when designing an effective surveillance monitoring system. In the on-going process of monitoring system optimization, it will always be necessary to re-evaluate the conceptual model, based on new monitoring data, and to use the revised, and more accurate conceptual model to re-evaluate the monitoring system. This process provides continual improvement to the system as well as greater value to the users of ground water surveillance monitoring data. 4. MONITORING NETWORK DESIGN . a. What Constitutes a Monitoring Network ? “An EMS must ensure the early identification of, and appropriate response to, potential adverse environmental impacts associated with DOE operations” What Constitutes a Monitoring Network? The gGround water monitoring wells, vadose zone monitoring techniques, piezometers, springs, seeps, and any other observation points where measurements are taken constitute the site-wide ground water monitoring network. Each observation point should be a component of one or more unique facility-specific or area-specific monitoring networks. A facility-specific monitoring network is a unique set of ground water observation points designed to detect releases to the subsurface that have affected the ground water or may cause ground water impacts in the future. A series of ground water and vadose zone monitoring wells and methods that have been placed up and down gradient from,, and below,, an operating facility (e.g., a reactor, an accelerator, a low-level radioactive waste disposal unit, etc.) is an example of a facility-specific network is an example of a facility-specific network. The information provided by this network of wells will allow site managers to determine whether any releases from the facility are occurring that may trigger specific actions included in the site-wide contingency plan, discussed in Section III3. An area-specific monitoring network is a unique set of ground water observation points designed to monitor existing subsurface conditions (i.e., hydrological parameters, as well as and contaminant concentration levels) to determine if significant deviations from expected conditions are observed that may warrant further investigation. An example of an area-specific network is a series of wells designed to monitor a contaminant plume where active remediation has ceased and monitored natural attenuation is being implemented. Another example is a series of wells within the site boundary designed to determine whether contaminants from any one of a number of possible sources may potentially affect off-site ground water resources. A series of monitoring wells designed to measure the effectiveness of active remediation of a contaminant plume, of a contaminant plume,as a component of a CERCLA or RCRA remedial action,, is another type of ground water monitoring network. This type of network, which is typically developed and described in a regulatory compliance document, should, however, also be included in a surveillance monitoring network, either network, either facility-specific or area-specific. The mMonitoring that is performed to comply with external regulatory requirements provides the framework for the long-term monitoring program that will provide surveillance and site maintenance information for closed waste management units and passive remediation sites. Eventually, active remediation sites (currently currently managed by the Office of Environmental Management) will be closed (i.e., active remediation will be completed) and post-closure monitoring and maintenance will become the responsibility of the appropriate DOE program offices and field elements. The monitoring network developed to provide information on current remediation activities should continue to be modified to address the needs for long-term site surveillance of the site. The description of the site-wide surveillance monitoring network, and identification of facility-specific and area-specific networks should be included in a site-wide monitoring plan, as discussed later in this section. Each network should be made up of designated wells or observation points. The plan should specify frequency of sampling and specific data to be obtained from each well at each sampling event. Each network design should be based on the conceptual site model (discussed in Section III3), and should be regularly re-evaluated based on numeric modeling using monitoring network results. b. Basic Understanding of the Flow System . An effective monitoring system mustshould be designed with full consideration of the site-wide hydrologic conditions. Location of subsurface observation points (i.e., monitoring wells, piezometers, temporary wells, seeps, springs, etc.) mustshould be determined on the basis of an adequate understanding of the local flow system, with consideration of and the chemical and physical properties of the analytes that will be monitored. Understanding the local flow system is critical to the predictingon of potential contaminant migration pathways relative to from a facility or activity that may eventually release contaminants to the subsurface. A surveillance monitoring network that is designed and operated to for early detection of , as early as possible, any future releases to the subsurface at a specific facility would be completely ineffective if the wells that constituted the monitoring network were located where they would not intercept a contaminant plume, should one occur, due to a lack of understanding of the local flow system. , should one occur, due to a lack of understanding of the local flow system. Releases to the subsurface that go undetected for many years due to a monitoring network designed without careful attention to the local flow system may result in significant impacts on the ground water and perpetuation of the expensive and, in some cases intractable, contamination events that the Department is now addressing. Periodic re-evaluation of the local flow system is necessary to account for seasonal fluctuations in water usage, rainfall, snowmelt, etc., that may affect local flow, as well as, as well as physical changes in site facilities, structures, or operating practices. Examples of physical changes at the site that may impact the local flow system include the following: (1) removal of a building and its utility lines (sewer, water supply, process liquid conduits, etc.); (2) pavement of previously unpaved land; (3) drainage and removal from operations of water retention basins, settling ponds, impoundments, etc.; (4) repair or replacement of water lines that had been leaking significant quantities of liquid to the subsurface. Additionally, cCertain types of DOE facilities at DOE sites are operated only periodically during the course of a typical year. When in operation, the facility may use and discharge significant quantities of water for operational purposes (e.g., primary or secondary cooling, other processing). When the facility is not in operation, water use ceases or is drastically reduced. These sporadic operations can have significant, but temporary, impacts on the local flow system. Such impacts should be anticipated and should be fully accounted for in the design of a surveillance monitoring network and in interpreting the results. c. DQO Process aApplied to Network Design . The design of a ground water surveillance monitoring network should be based on a systematic process for asensuring that the data produced by the network will effectively meet the end user=’s needs. The Data Quality Objectives (DQO) (EPA 2000) process has been employed for the design of environmental data collection and monitoring systems, and is quite suitable for the design of an effective ground water surveillance monitoring network. The basic steps in the DQO process are the following. : (1) State the Problem . - It is important to state the basic purpose of the surveillance monitoring network as unambiguously as possible. For example, tThe following statement may satisfy the need to state the problem unambiguouslywould be acceptable: AMonitoring of the ground water for increased levels of tritium should be performed to determine whether tritium is being released from the XYZ reactor. It is necessary to maintain a series of monitoring wells (at least three) immediately down-gradient of the XYZ reactor, screened in the upper 10 feet of the water table aquifer, to detect increased levels of tritium of greater than 25 percent over baseline levels, that may indicate a release of tritium from the reactor.@ . An adequate monitoring network for this facility could be designed to meet the problem stated here. (2) Identify the Decision . - The surveillance monitoring network should be designed to provide sufficient information to ensure that appropriate actions are taken at the appropriate time. In the example above, the information that would be obtained from the network whenever the wells are were sampled is whether the tritium levels in the water table aquifer have increased by 25% percent over baseline levels, that to indicates that a release may have occurred and would trigger an investigation. (3) Identify the Inputs to the Decision . - Inputs to the design of the surveillance monitoring system includes, at a minimum,— (a) the nature of the facility or activity to be monitored, the type of contaminant that may be released to the subsurface, (b) the local ground water flow system and how it responds to seasonal or episodic perturbations, (c) the frequency by which decisions need to be taken on whether responses are needed, and (d) the consequences of not making appropriate and timely responses. Additional input includes certain “metadata” related to theon samples that provide crucial information for complete and correct interpretation of the results. Such mMetadata, which should be identified in the monitoring plan, include include— (a) sampling procedures, (b) analytical methods, and any (c) qualifiers placed on the monitoring results during data validation. (4) Define the Boundaries of the Problem . - For a specific surveillance monitoring network, it is important to identify the physical (spatial and temporal) boundaries of the facility or activity, as well as and the physical, legal, or other institutional barriers to the network design. A potential future source of contamination could impact off-site ground water resources. If this is the case, there may be legal or political barriers that would affect the design of the network. If the facility or activity encompasses a very large area (e.g., square miles, or thousands of acres), the network mustshould be designed to minimize potentially excessive costs without significant reduction in effectiveness. Additionally, if the ground water occurs at substantial depth below ground the surface or below the point where a potential future release may occur, there may be a significant period of time between the first occurrence of a release and the actual arrival of the contaminant in the ground water. Considerations such as these should be made in the design phase to ensure that the network will function effectively, once it is implemented. (5) Develop a Decision Rule . - A decision rule, or set of rules, that describes, as quantitatively as possible, the outcomes or actions to be taken, based on the range of monitoring network results, is important in the design of the a network. If the decision rule is fairly simple and easily stated in quantitative terms, the design of the network should be relatively straightforward. For example, a series of monitoring wells that are sampled quarterly to detect the release of a specific chemical should be governed by a fairly simple rule such as the following AIf any level of chemical X is detected above the method detection level, then the following actions will be taken: . . . . If the decision rule is more complicated, in that a large number of samples mustshould be taken and analyzed for a number of parameters, which may lead to various potential responses, then a more elaborate network design may be warranted. (6) Specify the Tolerable Limits on Decision Errors . - It is important to consider possible types of errors and their related consequences, during as part of the network design. of the network. Depending on the decision rule, it is possible that a failure to detect the an identified contaminant, or the failure to take immediate action, or the taking of an action based on a false positive may have either minor or severe consequences, or may have either and immediate or longer- term consequences. The range of reasonable scenarios and their expected consequences should be carefully considered carefully when designing a surveillance monitoring network. (7) Optimize the Design for Obtaining Data . - The endpoint of the DQO process is to conceive of the optimal network design - i.e., a design that is responsive to the needs and constraints identified previously, and that balances those considerations with cost to create and maintain the network. The specific network features arrived at through this process should be sufficiently detailed to allow the construction of a monitoring system and the development of a sampling plan. d. Ground Water Monitoring Plan . Each site should prepare a site-wide ground water surveillance monitoring plan, primarily for internal use. The plan should be structured so as to be as useful as possible for site managers and technical staff. It should be and updated, as appropriate, to accurately reflect current designs and operations of the site-wide network, and to provide descriptions of future plans to improve or optimize the ground water monitoring network. Additionally, the The plan should serve as a historical record of the ground water monitoring program, as it changes and evolves over time. There is no set format or single approach that each DOE site should follow in developing this plan. The most important criterion as to the structure of the plan is whether it is useful to site personnel. There are a number of eThere are a number of elements that should be included, where appropriate, that should be included, where appropriate, in eachin each site’s s monitoring plan. The following section lists the basic elements of a ground water monitoring plan. The following lists the basic elements of a ground water surveillance monitoring plan: (1) Network design, that associates each well or other observation point with a facility-specific or area-specific surveillance monitoring network. (2) Monitoring methods (e.g.,such as wells, cone penetrometers, temporary wells, piezometers, vadose zone monitoring, etc., and), as well as seeps, springs, and other observation points. (3) Sample type, frequency, analytes, and the protocols followed at each well or other observation point, to indicate the information to be provided to meet the purpose of the specific network. (4) Responsibilities for each aspect of the site-wide network, to include organizational designations , as well asand actual points of contact. (5) Process description that details the flow of data from the time a sampling event is requested, to the point at which specific final results are transmitted to the end user. (6) References to specific technical documents that contain detailed information needed for day-to-day operations, including geologic and hydrologic studies, and modeling analyses that form the technical basis for the monitoring network. (7) Descriptions of data management systems and reporting procedures. (8) References to historical documents and data that describe the technical and organizational aspects of the program throughout the site’s history. The site-wide monitoring plan should contain an information management component that addresses the needs of present and future the current monitoring data users as well as the needs of potential future users. There should be a detailed process for ensuring that the sampling data generated during each sampling event is evaluated as appropriately to meet the needs of current data users, and is maintained for future analyses. The plan should describe quality control and quality assurance procedures, and indicate how the data is classified according to any qualifications on its accuracy and precision. The monitoring plan should describe the process for storing data on the sampling procedures employed and on the analytical methods used by each laboratory, and the process to be followed by future data users for obtaining specific quality assurance and quality control and metadata information. The plan should describe the long termlong-term repository for each type of data and the procedures for data retrieval. 5. INTEGRATION OF THE GROUND WATER MONITORING NETWORK . “As part of integrating EMSs into site ISMSs, DOE elements must consider the implementation of a site-wide approach for groundwater protection” Consistent with the requirements of Order DOEDOE O 450.1 and with the stated objective to be achieved byto be achieved by a site-wide EMS, an integrated ground water surveillance monitoring network should replace the fragmented, independent monitoring system that has typically been developed at many DOE sites. should replace the fragmented monitoring system that has typically been developed at many DOE sitesHistorically, ground water monitoring activities activities at DOE sites haveve been undertaken in response to an immediate need, and are frequently determined through a negotiation process with external regulators who are implementing a single regulatory program (e.g., RCRA, CERCLA, etc.) at a single operable unit, waste area grouping, or waste management facility. Monitoring that is being being conducted and funded by a specific DOE program for a specific facility or area at a site is not always coordinated with other monitoring activities at the same site. At certain DOE sites, surveillance monitoring has been conducted by taking samples wherever they wherever they can be quickly, easily, and inexpensively obtained obtained (e.g., from a seep or spring, or from an existing production well). As a result of these historical circumstances, a fragmented monitoring system has been developed at many DOE sites. In addition to the physical fragmentation of site-wide monitoring is the lack of a single organization that is responsible and accountable for ground water monitoring across the entire site. Where organizational responsibilities are fragmented, program funding sources are generally fragmented as well. An integrated ground water surveillance monitoring network, however, should evolve from the typical fragmented system to provide results that meet regulatory compliance requirements and commitments,, that meet that meet management needs for operating program information (including waste management, stewardship, restoration, institutional controls, etc.),, and that should function in a manner that allows demonstration of cost-effectiveness. The integrated, site-wide ground water surveillance monitoring program should be capable of providing adequate quality data for all program needs, and should ensure efficiency and cost-effectiveness by avoiding duplication. The concept of an “integrated monitoring program”The concept of an Aed program@ is based on avoiding or eliminating numerous systems and procedures and their their associated costs for achieving the same or similar goals. Ground water monitoring mustshould be viewed as a site-wide activity, and the provision of ground water monitoring data as a service that meets the needs of any individual program or activity. There is no justification for a separate ground water monitoring program for each each specific DOE program function or activity at any DOE site. There should be no no designation of certain monitoring wells as “Alandlord’@ wells and others as “Aprogram office”@ wells or “Arestoration”@ wells. There should be no . There should be no separate databases for managing data from each program=s individual programs’ monitoring system. There should be only one site-wide organization that routinely manages the integrated system,, by accepting requests for sampling events, scheduling and facilitating sampling events, requests for sampling events, scheduling and facilitating sampling events, providing results per the the requestor=s’ specifications to include adequate but not excessive quality assurance and quality control, , and ensuring coordination across all site-wide program activities. There should be one designated site-wide source for data requests for current or historical ground water monitoring informationinformation. This single source should be responsible for providing all of the of the data needed by any any program at the site at the site forfor meetinging reporting requirements and for for respondinging to management information needs. 6. GROUND WATER MONITORING PROGRAM EVALUATION . “An EMS includes measurable environmental goals, objectives, and targets that are reviewed annually and updated when appropriate” At most DOE sites, ground water monitoring will be conducted for surveillance purposes for many years, possibly for many decades, as well as,possibly for many decades, as well as for regulatory compliance in the relative short term. Given the long-term, on--going nature of ground water surveillance monitoring, there is a need for periodic evaluation of the the site-wide program. Each site should establish a process for determining whether the existing program is providing useful information to its clients, to its clients, and is being operated and managed effectively. Following are some suggested criteria for periodic ground water surveillance monitoring program evaluations. a. Criteria for evaluating DOE site-wide ground water surveillance monitoring programs a. To effectively manage ground-water resources, DOE site-wide monitoring programs should meet the following criteria: a. Ambient Quality of the Ground Water Resource . The monitoring program provides quantitative information on ground water quality in a consistent manner in a consistent manner across the site,, consistent consistent from year to year. Ground water quality data includes the levels of natural constituents (chemical, biological, radiological, and physical characteristics), as well as the of uncontaminated ground water, as well as the types and levels of contaminants in ground water across the site. b. Specific Data Needs . The monitoring program provides the specific ground water quality data needed for resource management and regulatory compliance. Specific ground water quality data is needed . Specific ground water quality data is neededfor planning, designing, and operating facilities related to site missions, including environmental protection and pollution prevention activities, as well as activities, as well as demonstratingdemonstrating compliance with regulatory requirements, and on-going assessment of performance of waste management and disposal units performance. c. Scope of Site-Wide Monitoring . The monitoring program should document includes a description of the current numbers of wells, numbers of number of samples per well per year, number of number of analyses per sample, , etc., and should provide a quantitative basis for estimating future modifications to the site-wide network, including a schedule for monitoring well replacement and abandonment. d. Purpose and Design of Monitoring Network . The monitoring program defines the purpose((s)) for monitoring the ground water,, and the the design of network((s)) related to each purpose. The monitoring program is reviewed regularly to ensure that the monitoring network(s) adequately meets address these purposes. e. Data Management . The monitoring program is capable ofassures that the users are getting the right data, enough data, adequate quality data, and not getting superfluous data. Historic data are retained and are retrievable for future use. f. Ensuring Efficiency and Cost Effectiveness . The monitoring program provides the minimum necessary ground water data at the appropriate quality at the lowest cost. The monitoring program includes a method for demonstrating that costs are justified. g. Utility of the Monitoring Data . The monitoring program provides data that meets the needs of the users. The monitoring program provides data that meets the needs of the users. A process is developed to enassure that the monitoring data satisfies the users’ needs and is being used effectively by the users. h. Continuous Improvement of Existing Monitoring Programs . Monitoring methods that reduce the costs of the monitoring program without reducing the amount or quality of the data are regularly being investigated and adopted, where appropriate., where appropriate. i. Alternative Monitoring Methods . Alternatives to conventional monitoring methods that will provide adequate data for meeting the purposes of the monitoring program purposes are regularly being investigated and adopted, where appropriate, where appropriate. j. Analysis of Trends . The monitoring program includes analyses of trends in ground water quality, across all areas of all areas of the site. Each site’s analyses allow similar review of long-term trends collectively at all DOE sites. Summarized data on the size, scope, and results of the site-wide ground water monitoring program should be easily obtainable from the site’s data management system, and should be included in the Aannual Ssite Eenvironmental Rreport in a manner consistent with EH-4annual guidance prepared by the Office of Environment, Safety and Health, to allow consistent Department-wide analyses of program the performance. of the program. 7. SURVEILLANCE MONITORING PROGRAM FUNDING . “Ensure site annual budgetary processes include the funding and resources needed to implement this Order” “Conduct environmental monitoring to detect, characterize, and respond to releases from DOE activities” “Ensure the analytical work supporting environmental monitoring is implemented using A consistent system for data collection and analysis A valid and consistent approach for sampling and analysis An integrated sampling approach to avoid duplication” Ground water surveillance monitoring is an activity that is an activity that will be conducted at many DOE sites for many years. Where wastes remain after all other site all other site operational activities are have been completed and the the site is closed due toafter active completion of environmental restoration has been completed, and even where no releases from any disposal units have occurred, there will continue to be a need for ground water surveillance monitoring. This is especially true where the area of the site that is dedicated the area of the site that is dedicated to waste management is in is in close proximity proximity to lands and facilities that are no longer under any formal any use restrictionss. Industrial, residential, or recreational land use at former DOE sites may be subject to future threats releases if long-term surveillance monitoring is not faithfully conducted where wastes or contaminated areased areas remains. Each DOE site and each DOE each DOE program that is associated with a DOE site that is associated with the DOE site mustshould request sufficient resources in the annual budgetary process to support the site-wide surveillance monitoring network. Annual budgets should be prepared to include a specific request for funding and staffing of the site-wide program as a line item, recognizing the continued long-term importance of the network in meeting Order DOEDOE O 450.1 requirements and ensuring effective environmental stewardship. If DOE program and site-wide budgets do not typically address environmental monitoring as a specific budgetary item, the possibility exists that a site-wide surveillance monitoring program may not be adequately funded. Consistent with an integrated ground water monitoring program is the need for an integrated site-wide funding source for ground water monitoring program activities program activities. The site-wide needs for well construction/abandonment, sampling and analysis, data management and reporting, QA/QC, etc., should be addressed in a composite budget request, rather than in a fragmented or piecemeal fashion. Each DOE program office that is responsible for any facility, program, or activity at a specific DOE site that may impact ground water resources should provide its share of the cost for fully funding the integrated site-wide surveillance monitoring program. This is important from a corporate, as well as and a site-wide DOE management perspective,, since an integrated budget identifies the full costs associated with operating a site-wide ground water monitoring program. Management can determine the full cost of sampling and analyzing ground water, as well as and demonstrating the cost-effectiveness of monitoring system improvements with a single budgetary amount for the full site-wide program. 8. REFERENCES :. a. 10 CFR PR, Part 830,. Nuclear Safety Management. b. DOE 2003. DOE O 450.1., Environmental Protection Program, (dated 1/-15/-03). (online at http://www.directives.doe.gov/pdfs/doe/doetext/neword/450/o4501.html). c. DOE 2001. DOE O 435.1. , Radioactive Waste Management (, dated 8/-28/-01). (online at http://www.directives.doe.gov/pdfs/doe/doetext/neword/435/o4351c1.html http://www.directives.doe.gov/pdfs/doe/doetext/neword/435/o4351c1.pdf). (http://www.directives.doe.gov/pdfs/doc/doetext/neword/435/o4351c1.html) d. DOE 2001a. DOE M 435.1-1., Radioactive Waste Management Manual (, dated 6/19/-01). (online at http://www.directives.doe.gov/pdfs/doce/doetext/neword/435/m4351-1c1.html). e. DOE 1999. DOE G 435.1-1., Chapter 4. , Low-Level Waste Requirements (, dated 7/-9/-99). (online at http://www.directives.doe.gov/pdfs/doec/doetext/neword/435/g4351-1ch4.html). f. DOE 1993. DOE O 5400.5., Radiation Protection of the Public and the Environment (, dated 1/7/-93) (online at http://www.directives.doe.gov/pdfs/doec/doetext/oldord-/5400/o54005c2.html) g. DOE 1991. DOE/-EH-0173T. Environmental Regulatory Guide for Radiological Effluent Monitoring and Environmental Surveillance (, dated 1/January 1991). (online at http://tis.eh.doe.gov/oepa/guidance/aea/effluent/eh0173t.pdf). h. EPA-600-R-00-007, EPA 2000. Data Quality Objectives Process for Hazardous Waste Site Investigations. EPA/600/R-00/007. January 2000. (online at http://www.epa.gov/quality1/qs-docs/g4hw-final.pdf). DISTRIBUTION: INITIATED BY: All DOE Organizations Office of Environment, Safety and Health DOE G 450.1-6 i (and ii) DRAFT XX-XX-04 iv DOE G 450.1-6 DRAFT XX-XX-04 DOE G 450.1-6 iii (and ii) DRAFT XX-XX-04 18 DOE G 450.1-6 DRAFT XX-XX-04 DOE G 450.1-6 17 DRAFT XX-XX-04 DOE G 450.1-6 1 DRAFT XX-XX-04

DOE G 450.1-6 Draft 450.1-6 Ground Water Surveillance Monitoring Implementation Guide for Use with DOE O 450.1, Environmental Protection Program <AUTHOR> James Bachmaier <AUTHOR_EMAIL> James.Bachmaier@eh.doe.gov <AUTHOR_PHONE> (202)586-0341 <ORG> EH <SandH> N <SUMMARY> The purpose of this Guide is to assist DOE sites in establishing and maintaining surveillance monitoring programs to detect future impacts on ground water resources from site operations and to assess potential for exposing the general public to site releases. <DATE_ISSUE> 03/24/2004 <DATE_CLOSE> <DATE_REVIEW> <TEXT> DOE G 450.1-6 DRAFT MARCHXX-XX-2004 Ground Water Surveillance Monitoring Implementation Guide for uUse with DOE O 450.1, Environmental Protection Program [This Guide describes suggested nonmandatory approaches for meeting requirements. Guides are not requirements documents and are not to be construed as requirements in any audit or appraisal for compliance with the parent Policy, Order, Notice, or Manual.] U.S. Department of Energy Washington, D.C. 20585 PREFACE DOE G 450.1-6, Ground Water Surveillance Monitoring Implementation Guide for Use with DOE O 450.1, Environmental Protection ProgramThis Guide is one of a series of Guides issued to provide suggested approaches for meeting the requirements of DOE O 450.1 Environmental Protection Program, dated 1-15-03, which. DOE O 450.1 requires Department of Energy (DOE) elements Organizations to establish an Environmental Management System (EMS) that is integrated intopart of DOE’s Integrated Safety Management System (ISMS). DOE G 450.1-6 This Guide provides a description of the elements of an integrated site-wide ground water surveillance monitoring program that can be adapted to unique physical conditions and programmatic needs at each DOE site to meet the requirements of DOE O 450.1. CONTENTS 1. INTRODUCTION 1 2. DOE REGULATIONS AND ORDER REQUIREMENTS RELATED TO GROUND WATER MONITORING 2 a. 10 CFR, Part 830, Nuclear Safety Management 3 b. DOE O 450.1, Environmental Protection Program 3 c. DOE O 5400.5, Radiation Protection of the Public and the Environment 4 d. DOE O 435.1, Radioactive Waste Management and DOE M 435.1-1, Radioactive Waste Management Manual 4 3. SURVEILLANCE MONITORING 5 a. Objectives for the Design of a Site-wide Surveillance Monitoring Network 5 b. Contingency Plans 7 c. Site-wide Review of Historic and Current Operations and Practices 7 d. Prioritization of Vulnerable Areas of the Site 8 e. Subsurface Characterization and Hydrology 8 4. MONITORING NETWORK DESIGN 9 a. What Constitutes a Monitoring Network 9 b. Basic Understanding of the Flow System 10 c. DQO Process Applied to Network Design 11 (1) State the Problem 11 (2) Identify the Decision 11 (3) Identify the Input to the Decision 12 (4) Define the Boundaries of the Problem 12 (5) Develop a Decision Rule 12 (6) Specify the Tolerable Limits on Decision Errors 13 (7) Optimize the Design for Obtaining Data 13 d. Ground Water Monitoring Plan 13 5. INTEGRATION OF THE GROUND WATER MONITORING NETWORK 14 6. GROUND WATER MONITORING PROGRAM EVALUATION 15 a. Ambient Quality of Ground Water Resource 16 b. Specific Data Needs 16 CONTENTS (continued) c. Scope of Site-Wide Monitoring 16 d. Purpose and Design of Monitoring Network 16 e. Data Management 16 f. Ensuring Efficiency and Cost Effectiveness 16 g. Utility of the Monitoring Data 16 h. Continuous Improvement of Existing Monitoring Programs 16 i. Alternative Monitoring Methods 16 j. Analysis of Trends 17 7. SURVEILLANCE MONITORING PROGRAM FUNDING 17 8. REFERENCES 18 GROUND WATER SURVEILLANCE MONITORING IMPLEMENTATION GUIDANCE 1. INTRODUCTION . The purpose of this guidance is to assist each DOE sites in establishing and maintaining a surveillance monitoring programs to detect future impacts on ground water resources from site operations and to assess potential for exposingure to the general public to site releases. This implementation guidance guidance— * describes the essential elements of a site-wide ground water surveillance monitoring network,. The guidance * distinguishes the objectives of a surveillance network from a network designed to meet specific external regulatory requirements related to restoration,. It * distinguishes short termshort-term monitoring program goals from long termlong-term stewardship monitoring goals, and. It also * addresses the integration of existing ground water monitoring activities into the site-wide monitoring network. In addition to providing real- time environmental measurements for estimating potential human dose, the site-wide ground water surveillance monitoring system must should provide a mechanism for detecting releases to the subsurface environment from a DOE facility or activity that will trigger an appropriate response, to prevent or minimize adverse impacts on ground water resources. The emphasis of this guidance is the creation and maintenance of a site-wide surveillance monitoring program at each DOE site that to serves as the basis for long-term surveillance for environmental stewardship. This document provides guidance (Section II2 of this Guide) addresses for integrating internal and external ground water monitoring requirements contained in the following. * Title various DOE regulations (10 Code of Federal Regulations (CFR), Part 830,) Nuclear Safety Management. and * Orders (Order DOE O 450.1, Environmental Protection Program, dated 11503. Order * DOE O 5400.5, Radiation Protection of the Public and the Environment, dated 17-93. and Order * DOE O 435.1, Radioactive Waste Management), dated 8-28-01. * DOE M 435.1-1, Radioactive Waste Management Manual, dated 6-19-01. * DOE G 435.1-1, Chapter 4, Low-Level Waste Requirements, dated 7-9-99. It This Guide is a companion document to AEnvironmental Regulatory Guide for Radiological Effluent Monitoring and Environmental Surveillance@ (DOE-/EH-0173T, January 1991). Unlike EH0173T, though, this guidance addresses addresses radiological and non-nonradiological ground water monitoring. It does not, however, address the technical aspects of monitoring well construction, sampling or analytical techniques, or innovative technology. Section 3 addresses . It does not address the technical aspects of monitoring well construction, sampling or analytical techniques, or innovative technology. It does address, however, the objectives of a site-wide surveillance monitoring program in the context of internal DOE Order requirements for environmental protection, with emphasis on the maintenance and continual optimization of a network designed to provide surveillance over extended periods of time. . It also addresses It also addresses vadose zone monitoring as an integral component of a ground water surveillance monitoring network.; and Section IV4 discusses the concept of a site-wide monitoring network and the technical basis for its design. Although it is important to design a unique ground water monitoring network that provides information for meeting each specific program objective (i.e., external regulatory requirements, DOE Order requirements, etc.), it is also necessary to integrate the individual networks in such a way that individual monitoring wells can be incorporated into more than one network, as appropriate, to achieve cost efficiencies and to optimize the information provided by each well. This guidance also addresses (Section 5) the integration of DOE Order requirements for surveillance monitoring with requirements of external regulations [(the Resource Conservation and Recovery Act (RCRA), the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), etc.)] for compliance monitoring. Section VI6 discusses the site-wide program and the need for continuingal program evaluation as site conditions change over time, and provides suggested criteria for monitoring program optimization. Section VII7 addresses the need for asensuring adequate funding for the on-going, site-wide program. 2. DOE REGULATIONS AND ORDER REQUIREMENTS RELATED TO GROUND WATER MONITORING . There are specific requirements contained in various DOE Orders that relate to the sitewide ground water surveillance monitoring network. The following discussion cites each specific requirement. Each DOE site mustshould meet these requirements in a manner that is appropriate for the site’s unique conditions. It is important, however, for each DOE site to consider the integration of these requirements in designing and upgrading a surveillance monitoring network that is cost effective. a. 10 CFR PR, Part 830, – Nuclear Safety Management . 10 CFR Part 830 requires that aAll DOE nuclear facilities shouldmust perform work in accordance with a safety basis that ensures adequate protection of workers, the public and the environment. According to DOE’s General Statement of Safety Basis Policy (Appendix A to Subpart B of 10 CFR, Part 830, Subpart B, Appendix A), the safety basis requirements are generally met by a site-wide Integrated Safety Management System (Integrated Safety Management System (ISMS)) that includes programs that adequately protect the environment. A ground water surveillance monitoring program, with appropriately designed networks for each nuclear facility subject to 10 CFR PR Part 830,, is an integral component of the site-wide ISMS, and must should be developed and maintained to asensure compliance with 10 CFR PR Part 830. b. Order DOE O 450.1, – Environmental Protection Program (DOE 2003) . Order DOE O 450.1 (issued dated January 15, 2003)The Order requires that each DOE site implement an Environmental Management System (EMS) as part of the site=‘s Integrated Safety Management SystISMSem. The site-wide The EMS must shouldprovide for the systematic planning, integrated execution, and evaluation of programs that ensure be designed to do the following:public health and environmental protection, pollution prevention and compliance with DOE Directives and applicable laws and statutes. An effective EMS should integrate plans, procedures, and program assessment and corrective actions. (1) Provides for the systematic planning, integrated execution, and evaluation of programs for - (a) public health and environmental protection, (b) pollution prevention (P2), and (c) compliance with applicable environmental protection requirements. (2) Includes policies, procedures, and training to identify activities with significant environmental impacts, to manage, control, and mitigate the impacts of these activities, and to assess performance and implement corrective actions where needed. (3) Includes measurable environmental goals, objectives and targets that are reviewed annually and updated when appropriate. DOE sites are responsible for an EMSs that will ensure the early identification of “Ensure the early identification of, and appropriate response to,adverse environmental impacts associated with from DOE operations, as well as ensure that appropriate responses are taken. and surveillance monitoring.” DOE facilities are responsible for integrating the EMS into the ISMS to: consider, as appropriate, the protection of * surface and ground water, (b) implementation of a watershed approach for protection,(c) implementation of a site-wide approach for ground water protection, * (d) protection of other natural resources including and biota, * (e) protection of site resources from site resources from wildland and operational fires, and fires, and * (f) protection of cultural resources. DOE Ooperations/Ffield/Ssite Ooffice Mmanagers are responsible for implementing Order DOE O 450.1 requirements for— * annual budgetary planning and P2 program implementation and monitoring, by, among other requirements, completing the following: * Ensure environmental monitoring to detect, characterize, and respond to releases from DOE activities,. and Conduct, as appropriate, to * a consistent, validated approach for environmental sampling and analysis. (14) Ensure the analytical work supporting environmental monitoring is implemented using – (a) a consistent system for collecting, assessing, and documenting environmental data of known and documented quality; (a) a validated and consistent approach for sampling and analysis of radionuclide samples to ensure laboratory data meets program-specific needs and requirements within the framework of a performance-based approach for analytical laboratory work; and (a) an integrated sampling approach to avoid duplicative data collection. To achieve a fully integrated, site-wide ground water surveillance monitoring program and to meet the Order DOEDOE O 450.1 requirements noted above, DOE field and site office managers must develop the structure of the site-wide program, determine resource needs, evaluate program performance, and identify benefits to be obtained from an integrated program. Headquarters program office managers must provide consistent overall direction to their field and site office counterparts, and provide consistent funding to support the integrated program. Section V5 discusses program integration in more detail. Section VII7 discusses the need for a consistent source of funding for the integrated program. c. Order DOEDOE O 5400.5, - Radiation Protection of the Public and the Environment (DOE 1993) . Order DOEThe Order 5400.5 sets standards for DOE sites and DOE contractors that manage radioactive materials. It includes statements of DOE. It includes statements of DOE’s radiation protection program objectives. Protecting the Public. It is DOE=s objective to operate its facilities and conduct its activities so that radiation exposures to members of the public are maintained within the limits established in this Order and to control radioactive contamination through the management of real and personal property. It is also a DOE objective that potential exposures to members of the public be as far below the limits as is reasonably achievable (ALARA) and that DOE facilities have the capabilities, consistent with the types of operations conducted, to monitor routine and non-routine releases and to assess doses to members of the public. Protecting the Environment. In addition to providing protection to members of the public, it is DOE=s objective to protect the environment from radioactive contamination to the extent practical. Chapter I of DOE 5400.5 DOE sites must Effluent Monitoring and Environmental Surveillance Demonstration of Compliance. Ddemonstrateion of compliance, through effluent monitoring and surveillance. programs, with DOE O 5400.5 requirements of this Order generally will be based upon calculations that make use of information obtained from monitoring and surveillance programs. The abilities to for protecting the general public and the environment. Monitoring and Surveillance Requirements. The 5400 series of DOE Directives provide requirements for o ensuringe that the effluent monitoring and environmental surveillance programs are of good quality. at all DOE facilities and sites, certain requirements and recommendations are provided in DOE Orders in the 5400 series which deal with radiological effluent monitoring and environmental surveillance.DOE 5400.5, Chapter II, of DOE 5400.5 describes DOE’s policy on providing protecting the public and the environment from radiological releases protection of the public and the environment by setting a DOE Ppublic Ddose Llimit (100 mremmillirems, annual effective dose equivalent). , considering all exposure modes and all sources of radiation. ThisThe Chapter chapter also requires that “Ccompliance with the dose limits of this Order shall be demonstrated by documentation of include an appropriate combination of measurements and calculations to evaluate potential doses and the results of the the results of the evaluations.” The Order provides further direction on the specific monitoring requirements for compliance with the dose limits. Monitoring and Surveillance. General requirements for routine effluent monitoring are part of the environmental monitoring plan prescribed in DOE 5400.1. Specific requirements for radiological effluent monitoring and environmental surveillance and their schedule of implementation are prescribed in DOE Orders in the 5400 series, which deal with radiological monitoring and environmental surveillance. The monitoring requirements are applicable to all DOE and DOE contractor operations that are subject to the standards and requirements of this Order. Order DOE 5400.5 refers to the eEnvironmental monitoring programs developed to comply with Order DOEDOE O 5400.1 (General Environmental Protection Program) developed to comply with DOE 5400.1 should continue to be implemented, and should be revised, where appropriate, based on this guidance.. The recommendations contained in this guidance should be used to upgrade the site-wide monitoring programs to ensure that DOE O 5400.5 requirements continue to be met in an the effective and efficient manner. A fully integrated site-wide monitoring program should provide sufficient information on releases to the subsurface to allow estimates of radiological dose to demonstrate compliance with the DOE 5400.5 dose limits. d. Order DOEDOE O 435.1, - Radioactive Waste Management (DOE 2001)and DOE M 435.1-1, Radioactive Waste Management Manual . Order DOEDOE O 435.1 and DOE M 435.1-1 435.1 and DOE M 435.1-1 (DOE 2001a - Radioactive Waste Management Manual) contain specific requirements for management of radioactive waste, pursuant to DOE’s statutory authority (the Atomic Energy Act and related legislation). The purpose of DOE M 435.1-1 is to “...The Manual catalog thosedefines procedural requirements and existing practices that ensure that all DOE elements for DOE organizations and contractors continue to manage DOEs radioactive waste in a manner that is protectiveto protect of workers, the general and public, and safety, and the environment. ” Chapter I of DOE M M 435.1-1 identifies requirements for all DOE radioactive waste management facilities, as applicable, to include “eEnvironmental moMonitoring. at Rradioactive waste management facilities, operations, and activities that comply with DOE 5400.1 and DOE 5400.5. sh DOE M 435.1-1 contains additional monitoring requirements for all waste facilities (high level, transuranic, and low-level) to assure ensure that passive and active control systems have not failed. Additionally, DOE M 435.1-1The Manual also requires that low-level radioactive waste disposal facilities implement an environmental monitoring programs designed to “... include measureing and evaluateing releases, migration of radionuclides, disposal unit subsidence, and changes in disposal site/facility and disposal site parameters that could affect long term performance. which may affect long term performance.” Although DOE M 435.1-1 requires monitoring that complies with other DOE Order requirements in the 5400 series, the guidance for specific types of radioactive waste management units that accompanies DOE 435.1-1 (e.g., DOE G 435.1-1 for Low-Level Radioactive Waste Management – DOE 1999) includes additional requirements guidance for long termlong-term disposal facility performance monitoring, including measuring to detect releases to the subsurface environment. 3. SURVEILLANCE MONITORING . “An EMS must include policies, procedures, and training to identify activities with significant environmental impacts” a. Objectives for the Design of a Site-wide Surveillance Monitoring Network . Surveillance monitoring is performed to detect, at the earliest possible time, any impact on ground water from an operating facility or practice at a DOE site. A surveillance monitoring network should include observation points located and sampled appropriately, based on prioritized areas of the site where the ground water may be particularly vulnerable to contamination. At many DOE sites, observation points are appropriately located in the unsaturated zone, since the occurrence of ground water that may be vulnerable to contamination from DOE activities is well below the surface (i.e., 100s hundreds of feet below ground surface or more). Early Ddetection of a release to the subsurface at the earliest possible time may necessitate vadose zone monitoring to detect releases before the ground water is affected. It is important to understand that the oObjectives of surveillance monitoring are likely to include,, but will be broader than,, the objectives of a monitoring network designed to control and remediate existing ground water contamination. Where active remediation is being implemented, pursuant to a CERCLA compliance agreement or a RCRA corrective action order, monitoring is performed to identify the dimensions of the contaminated area, to measure contaminant migration and changes ing contaminant concentrations over time, and to evaluate the effectiveness of the remedial action. Surveillance monitoring also mustshould also address areas of the site that are not already subject to external ground water monitoring requirements. Surveillance monitoring is performed to determine whether the ground water is being affected by any other site-wide operations that involve management of wastes or other materials that are a potential future source of contamination. The broader, longer -term objective of surveillance monitoring is to provide an early warning to trigger some appropriate response, if to unplanned releases to the subsurface should occur. As such, a surveillance monitoring network is designed to anticipate what could happen that may trigger a response according to the Ccontingency Pplan discussed below. The site-wide ground water surveillance monitoring network should be designed to meet specific short-term and long-term program objectives, which could be short term or long term. Short termShort-term objectives would typically consider active site-wide operations and facilities that are not already subject to external environmental protection requirements. Some examples of these facilities and activities include: * radioactive material storage areas; * research or production reactors; * underground and above ground liquid storage facilities and associated piping; * irrigation systems; * sanitary sewer systems; * industrial wastewater treatment systems; * vehicle repair and maintenance systems; * improperly constructed wells; * past practice waste management sites, including former soil column discharge sites; * abandoned wells; * surplus or decommissioned buildings; and * new construction sites. After considering the materials managed at each site and the vulnerability to contamination of ground water resources in the area, Ssurveillance monitoring networks should be designed, where appropriate, to detect the possibleany future releases to the subsurface from these and other such facilities and activities, after considering the materials managed at each site and the vulnerability to contamination of ground water resources in the area. Additionally, a site-wide ground water surveillance monitoring network should be designed to meet longer -term objectives, primarily for areas of the site where wastes and other subsurface contaminants will remain after all active site operations have ceased. These long long-term objectives, which may fall into the category of environmental stewardship, address closed waste disposal units and contaminated areas of the subsurface where active remediation has ceased. In such circumstances, physical containment measures and control systems , as well asand institutional access controls, have been established to provide primary long termlong-term care. Surveillance monitoring should be considered as a secondary or back-up control system. Its with the primary objective should be toof detecting a releases, should it occur, following from a failure of the primary controls. The ground water surveillance monitoring network should be reviewed periodically and revised as necessary. As time passes, conditions change and the efficiency of the monitoring network needs to be continuously re-evaluated. It is possible that certain facilities or practices that had been considered high priority areas for potential future releases to the subsurface no longer present any significant threat to the ground water resources. This could occur if a practice ceased (e.g., a material storage area has been moved), an active facility is no longer in operation, or hazardous or radioactive materials are no longer managed thereat the site. It is also necessary to periodically revise the sampling plan for the surveillance monitoring network to reflect changing conditions at the site. As historical data is gathered and analyzed, frequency of sampling and types of analyses performed may be re-evaluated and modified to provide more useful information. Optimization software is available to allow program managers to statistically determine the value of data provided by the monitoring network, and to propose modifications, where appropriate. b. Contingency Plans . A carefully prepared contingency plan is a critical element in a site-wide ground water surveillance monitoring network. Fundamentally, the contingency contingency plan identifies ranges of action levels and corresponding responses to be taken if there is positive detection of contaminants are detected or indicators in the surveillance monitoring network. The contingency plan should includedefine an appropriate actions or responses to detection of all positive detections, which could be a confirmed level of a contaminant releases associated with the a facility or practice that is the object of the surveillance monitoring network, or any positive detection of a contaminant that is unexpected or requires some investigation to determine the source of the contaminant. Appropriate actions or responses could range from a simple matter of comparison comparing monitoring results against a regulatory standard or a risk assessment guideline, to re-sampling more frequently in the future, to reporting the detection level to external regulators, to conducting a site investigation to determine the source and need for corrective action. The contingency plan also should also provide guidance on lines of authority and responsibility for invoking contingencies and for reporting and evaluating their results. The data quality objectives (DQO) process, described in Section IV4, should be followed in the development and revision of a site-wide contingency plan, as well as and in the design of a site-wide monitoring network. c. Site-wide Review of Historic and Current Operations and Practices . Each site should institutionalize a process for performing a periodic site-wide review of historic and current operations and practices that may have impacted affected ground water, or current practices that could have impact in the future. The site-wide review should be conducted to provide input to periodic re-evaluation and revision of the surveillance monitoring network. Although most DOE sites have performed site characterizations in the past to determine the extent of existing contamination, and therefore, the size and scope of the remedial actions needed, there is a need to periodically re-visit areas of the site that may not have been included in on-going remedial actions, but may have experienced impacts from current site-wide operations, or may be vulnerable to future contamination, as a resulting from of new site operations. at the site. The site-wide review of historic and current operations should be conducted at a frequency and at a scale that is appropriate for the site=‘s history and current or future mission. Such a review will have additional benefits, in that for new technical staff, who replace former staff, who will not have had the advantage of institutional memory, will have the in providing an opportunity to identify past practices that may be having an impact on the ground water that had not previously occurred or been detected. d. Prioritization of Vulnerable Areas of the Site . There should be a process for assigning priority to site areas of the site where ground water may be vulnerable to contamination and may, therefore, need to be included in the surveillance monitoring network. Such prioritization should be used to formulate future budget requests. Since budgetary and other constraints are always a limitation on the size and scope of the monitoring program, a system is needed to for prioritizeing potentially vulnerable areas of the site is needed. Whenever a review of site-wide historic and current operations and practices is performed, or whenever new activities, new construction, or new missions for existing facilities are initiated, there is a need to determine the vulnerability of local ground water resources, and to re-evaluate priorities for the current surveillance monitoring network. e. Subsurface Characterization and Hydrology . The bThe basic hydrogeologic conditions of the sitegic conditions of the site mustshould be identified and quantified to the extent possible to construct an adequate ground water surveillance monitoring network. Most DOE sites have extensive historical knowledge of subsurface geologic and hydrologic conditions and water quality monitoring results. It is important that this information be assessed consistently when designing or modifying a site-wide surveillance monitoring network. Frequently, models are employed to evaluate ground water conditions at a local area (a waste management unit or an area where active ground water remediation is being performed) or for a short-term purpose (e.g., for plume identification as part of a CERCLA remedial investigation). In designing a site-wide monitoring system, it is important to construct a site-wide conceptual model of the subsurface. This conceptual model should be based on observed data from previous subsurface investigations, and it should also be the basis for future characterization. It is important to perform a site-wide water balance to ensure that occurrence the occurrence and movement of water onto and away from the site, as well as and flow conditions within the site, are accounted for, when designing an effective surveillance monitoring system. In the on-going process of monitoring system optimization, it will always be necessary to re-evaluate the conceptual model, based on new monitoring data, and to use the revised, and more accurate conceptual model to re-evaluate the monitoring system. This process provides continual improvement to the system as well as greater value to the users of ground water surveillance monitoring data. 4. MONITORING NETWORK DESIGN . a. What Constitutes a Monitoring Network ? “An EMS must ensure the early identification of, and appropriate response to, potential adverse environmental impacts associated with DOE operations” What Constitutes a Monitoring Network? The gGround water monitoring wells, vadose zone monitoring techniques, piezometers, springs, seeps, and any other observation points where measurements are taken constitute the site-wide ground water monitoring network. Each observation point should be a component of one or more unique facility-specific or area-specific monitoring networks. A facility-specific monitoring network is a unique set of ground water observation points designed to detect releases to the subsurface that have affected the ground water or may cause ground water impacts in the future. A series of ground water and vadose zone monitoring wells and methods that have been placed up and down gradient from,, and below,, an operating facility (e.g., a reactor, an accelerator, a low-level radioactive waste disposal unit, etc.) is an example of a facility-specific network is an example of a facility-specific network. The information provided by this network of wells will allow site managers to determine whether any releases from the facility are occurring that may trigger specific actions included in the site-wide contingency plan, discussed in Section III3. An area-specific monitoring network is a unique set of ground water observation points designed to monitor existing subsurface conditions (i.e., hydrological parameters, as well as and contaminant concentration levels) to determine if significant deviations from expected conditions are observed that may warrant further investigation. An example of an area-specific network is a series of wells designed to monitor a contaminant plume where active remediation has ceased and monitored natural attenuation is being implemented. Another example is a series of wells within the site boundary designed to determine whether contaminants from any one of a number of possible sources may potentially affect off-site ground water resources. A series of monitoring wells designed to measure the effectiveness of active remediation of a contaminant plume, of a contaminant plume,as a component of a CERCLA or RCRA remedial action,, is another type of ground water monitoring network. This type of network, which is typically developed and described in a regulatory compliance document, should, however, also be included in a surveillance monitoring network, either network, either facility-specific or area-specific. The mMonitoring that is performed to comply with external regulatory requirements provides the framework for the long-term monitoring program that will provide surveillance and site maintenance information for closed waste management units and passive remediation sites. Eventually, active remediation sites (currently currently managed by the Office of Environmental Management) will be closed (i.e., active remediation will be completed) and post-closure monitoring and maintenance will become the responsibility of the appropriate DOE program offices and field elements. The monitoring network developed to provide information on current remediation activities should continue to be modified to address the needs for long-term site surveillance of the site. The description of the site-wide surveillance monitoring network, and identification of facility-specific and area-specific networks should be included in a site-wide monitoring plan, as discussed later in this section. Each network should be made up of designated wells or observation points. The plan should specify frequency of sampling and specific data to be obtained from each well at each sampling event. Each network design should be based on the conceptual site model (discussed in Section III3), and should be regularly re-evaluated based on numeric modeling using monitoring network results. b. Basic Understanding of the Flow System . An effective monitoring system mustshould be designed with full consideration of the site-wide hydrologic conditions. Location of subsurface observation points (i.e., monitoring wells, piezometers, temporary wells, seeps, springs, etc.) mustshould be determined on the basis of an adequate understanding of the local flow system, with consideration of and the chemical and physical properties of the analytes that will be monitored. Understanding the local flow system is critical to the predictingon of potential contaminant migration pathways relative to from a facility or activity that may eventually release contaminants to the subsurface. A surveillance monitoring network that is designed and operated to for early detection of , as early as possible, any future releases to the subsurface at a specific facility would be completely ineffective if the wells that constituted the monitoring network were located where they would not intercept a contaminant plume, should one occur, due to a lack of understanding of the local flow system. , should one occur, due to a lack of understanding of the local flow system. Releases to the subsurface that go undetected for many years due to a monitoring network designed without careful attention to the local flow system may result in significant impacts on the ground water and perpetuation of the expensive and, in some cases intractable, contamination events that the Department is now addressing. Periodic re-evaluation of the local flow system is necessary to account for seasonal fluctuations in water usage, rainfall, snowmelt, etc., that may affect local flow, as well as, as well as physical changes in site facilities, structures, or operating practices. Examples of physical changes at the site that may impact the local flow system include the following: (1) removal of a building and its utility lines (sewer, water supply, process liquid conduits, etc.); (2) pavement of previously unpaved land; (3) drainage and removal from operations of water retention basins, settling ponds, impoundments, etc.; (4) repair or replacement of water lines that had been leaking significant quantities of liquid to the subsurface. Additionally, cCertain types of DOE facilities at DOE sites are operated only periodically during the course of a typical year. When in operation, the facility may use and discharge significant quantities of water for operational purposes (e.g., primary or secondary cooling, other processing). When the facility is not in operation, water use ceases or is drastically reduced. These sporadic operations can have significant, but temporary, impacts on the local flow system. Such impacts should be anticipated and should be fully accounted for in the design of a surveillance monitoring network and in interpreting the results. c. DQO Process aApplied to Network Design . The design of a ground water surveillance monitoring network should be based on a systematic process for asensuring that the data produced by the network will effectively meet the end user=’s needs. The Data Quality Objectives (DQO) (EPA 2000) process has been employed for the design of environmental data collection and monitoring systems, and is quite suitable for the design of an effective ground water surveillance monitoring network. The basic steps in the DQO process are the following. : (1) State the Problem . - It is important to state the basic purpose of the surveillance monitoring network as unambiguously as possible. For example, tThe following statement may satisfy the need to state the problem unambiguouslywould be acceptable: AMonitoring of the ground water for increased levels of tritium should be performed to determine whether tritium is being released from the XYZ reactor. It is necessary to maintain a series of monitoring wells (at least three) immediately down-gradient of the XYZ reactor, screened in the upper 10 feet of the water table aquifer, to detect increased levels of tritium of greater than 25 percent over baseline levels, that may indicate a release of tritium from the reactor.@ . An adequate monitoring network for this facility could be designed to meet the problem stated here. (2) Identify the Decision . - The surveillance monitoring network should be designed to provide sufficient information to ensure that appropriate actions are taken at the appropriate time. In the example above, the information that would be obtained from the network whenever the wells are were sampled is whether the tritium levels in the water table aquifer have increased by 25% percent over baseline levels, that to indicates that a release may have occurred and would trigger an investigation. (3) Identify the Inputs to the Decision . - Inputs to the design of the surveillance monitoring system includes, at a minimum,— (a) the nature of the facility or activity to be monitored, the type of contaminant that may be released to the subsurface, (b) the local ground water flow system and how it responds to seasonal or episodic perturbations, (c) the frequency by which decisions need to be taken on whether responses are needed, and (d) the consequences of not making appropriate and timely responses. Additional input includes certain “metadata” related to theon samples that provide crucial information for complete and correct interpretation of the results. Such mMetadata, which should be identified in the monitoring plan, include include— (a) sampling procedures, (b) analytical methods, and any (c) qualifiers placed on the monitoring results during data validation. (4) Define the Boundaries of the Problem . - For a specific surveillance monitoring network, it is important to identify the physical (spatial and temporal) boundaries of the facility or activity, as well as and the physical, legal, or other institutional barriers to the network design. A potential future source of contamination could impact off-site ground water resources. If this is the case, there may be legal or political barriers that would affect the design of the network. If the facility or activity encompasses a very large area (e.g., square miles, or thousands of acres), the network mustshould be designed to minimize potentially excessive costs without significant reduction in effectiveness. Additionally, if the ground water occurs at substantial depth below ground the surface or below the point where a potential future release may occur, there may be a significant period of time between the first occurrence of a release and the actual arrival of the contaminant in the ground water. Considerations such as these should be made in the design phase to ensure that the network will function effectively, once it is implemented. (5) Develop a Decision Rule . - A decision rule, or set of rules, that describes, as quantitatively as possible, the outcomes or actions to be taken, based on the range of monitoring network results, is important in the design of the a network. If the decision rule is fairly simple and easily stated in quantitative terms, the design of the network should be relatively straightforward. For example, a series of monitoring wells that are sampled quarterly to detect the release of a specific chemical should be governed by a fairly simple rule such as the following AIf any level of chemical X is detected above the method detection level, then the following actions will be taken: . . . . If the decision rule is more complicated, in that a large number of samples mustshould be taken and analyzed for a number of parameters, which may lead to various potential responses, then a more elaborate network design may be warranted. (6) Specify the Tolerable Limits on Decision Errors . - It is important to consider possible types of errors and their related consequences, during as part of the network design. of the network. Depending on the decision rule, it is possible that a failure to detect the an identified contaminant, or the failure to take immediate action, or the taking of an action based on a false positive may have either minor or severe consequences, or may have either and immediate or longer- term consequences. The range of reasonable scenarios and their expected consequences should be carefully considered carefully when designing a surveillance monitoring network. (7) Optimize the Design for Obtaining Data . - The endpoint of the DQO process is to conceive of the optimal network design - i.e., a design that is responsive to the needs and constraints identified previously, and that balances those considerations with cost to create and maintain the network. The specific network features arrived at through this process should be sufficiently detailed to allow the construction of a monitoring system and the development of a sampling plan. d. Ground Water Monitoring Plan . Each site should prepare a site-wide ground water surveillance monitoring plan, primarily for internal use. The plan should be structured so as to be as useful as possible for site managers and technical staff. It should be and updated, as appropriate, to accurately reflect current designs and operations of the site-wide network, and to provide descriptions of future plans to improve or optimize the ground water monitoring network. Additionally, the The plan should serve as a historical record of the ground water monitoring program, as it changes and evolves over time. There is no set format or single approach that each DOE site should follow in developing this plan. The most important criterion as to the structure of the plan is whether it is useful to site personnel. There are a number of eThere are a number of elements that should be included, where appropriate, that should be included, where appropriate, in eachin each site’s s monitoring plan. The following section lists the basic elements of a ground water monitoring plan. The following lists the basic elements of a ground water surveillance monitoring plan: (1) Network design, that associates each well or other observation point with a facility-specific or area-specific surveillance monitoring network. (2) Monitoring methods (e.g.,such as wells, cone penetrometers, temporary wells, piezometers, vadose zone monitoring, etc., and), as well as seeps, springs, and other observation points. (3) Sample type, frequency, analytes, and the protocols followed at each well or other observation point, to indicate the information to be provided to meet the purpose of the specific network. (4) Responsibilities for each aspect of the site-wide network, to include organizational designations , as well asand actual points of contact. (5) Process description that details the flow of data from the time a sampling event is requested, to the point at which specific final results are transmitted to the end user. (6) References to specific technical documents that contain detailed information needed for day-to-day operations, including geologic and hydrologic studies, and modeling analyses that form the technical basis for the monitoring network. (7) Descriptions of data management systems and reporting procedures. (8) References to historical documents and data that describe the technical and organizational aspects of the program throughout the site’s history. The site-wide monitoring plan should contain an information management component that addresses the needs of present and future the current monitoring data users as well as the needs of potential future users. There should be a detailed process for ensuring that the sampling data generated during each sampling event is evaluated as appropriately to meet the needs of current data users, and is maintained for future analyses. The plan should describe quality control and quality assurance procedures, and indicate how the data is classified according to any qualifications on its accuracy and precision. The monitoring plan should describe the process for storing data on the sampling procedures employed and on the analytical methods used by each laboratory, and the process to be followed by future data users for obtaining specific quality assurance and quality control and metadata information. The plan should describe the long termlong-term repository for each type of data and the procedures for data retrieval. 5. INTEGRATION OF THE GROUND WATER MONITORING NETWORK . “As part of integrating EMSs into site ISMSs, DOE elements must consider the implementation of a site-wide approach for groundwater protection” Consistent with the requirements of Order DOEDOE O 450.1 and with the stated objective to be achieved byto be achieved by a site-wide EMS, an integrated ground water surveillance monitoring network should replace the fragmented, independent monitoring system that has typically been developed at many DOE sites. should replace the fragmented monitoring system that has typically been developed at many DOE sitesHistorically, ground water monitoring activities activities at DOE sites haveve been undertaken in response to an immediate need, and are frequently determined through a negotiation process with external regulators who are implementing a single regulatory program (e.g., RCRA, CERCLA, etc.) at a single operable unit, waste area grouping, or waste management facility. Monitoring that is being being conducted and funded by a specific DOE program for a specific facility or area at a site is not always coordinated with other monitoring activities at the same site. At certain DOE sites, surveillance monitoring has been conducted by taking samples wherever they wherever they can be quickly, easily, and inexpensively obtained obtained (e.g., from a seep or spring, or from an existing production well). As a result of these historical circumstances, a fragmented monitoring system has been developed at many DOE sites. In addition to the physical fragmentation of site-wide monitoring is the lack of a single organization that is responsible and accountable for ground water monitoring across the entire site. Where organizational responsibilities are fragmented, program funding sources are generally fragmented as well. An integrated ground water surveillance monitoring network, however, should evolve from the typical fragmented system to provide results that meet regulatory compliance requirements and commitments,, that meet that meet management needs for operating program information (including waste management, stewardship, restoration, institutional controls, etc.),, and that should function in a manner that allows demonstration of cost-effectiveness. The integrated, site-wide ground water surveillance monitoring program should be capable of providing adequate quality data for all program needs, and should ensure efficiency and cost-effectiveness by avoiding duplication. The concept of an “integrated monitoring program”The concept of an Aed program@ is based on avoiding or eliminating numerous systems and procedures and their their associated costs for achieving the same or similar goals. Ground water monitoring mustshould be viewed as a site-wide activity, and the provision of ground water monitoring data as a service that meets the needs of any individual program or activity. There is no justification for a separate ground water monitoring program for each each specific DOE program function or activity at any DOE site. There should be no no designation of certain monitoring wells as “Alandlord’@ wells and others as “Aprogram office”@ wells or “Arestoration”@ wells. There should be no . There should be no separate databases for managing data from each program=s individual programs’ monitoring system. There should be only one site-wide organization that routinely manages the integrated system,, by accepting requests for sampling events, scheduling and facilitating sampling events, requests for sampling events, scheduling and facilitating sampling events, providing results per the the requestor=s’ specifications to include adequate but not excessive quality assurance and quality control, , and ensuring coordination across all site-wide program activities. There should be one designated site-wide source for data requests for current or historical ground water monitoring informationinformation. This single source should be responsible for providing all of the of the data needed by any any program at the site at the site forfor meetinging reporting requirements and for for respondinging to management information needs. 6. GROUND WATER MONITORING PROGRAM EVALUATION . “An EMS includes measurable environmental goals, objectives, and targets that are reviewed annually and updated when appropriate” At most DOE sites, ground water monitoring will be conducted for surveillance purposes for many years, possibly for many decades, as well as,possibly for many decades, as well as for regulatory compliance in the relative short term. Given the long-term, on--going nature of ground water surveillance monitoring, there is a need for periodic evaluation of the the site-wide program. Each site should establish a process for determining whether the existing program is providing useful information to its clients, to its clients, and is being operated and managed effectively. Following are some suggested criteria for periodic ground water surveillance monitoring program evaluations. a. Criteria for evaluating DOE site-wide ground water surveillance monitoring programs a. To effectively manage ground-water resources, DOE site-wide monitoring programs should meet the following criteria: a. Ambient Quality of the Ground Water Resource . The monitoring program provides quantitative information on ground water quality in a consistent manner in a consistent manner across the site,, consistent consistent from year to year. Ground water quality data includes the levels of natural constituents (chemical, biological, radiological, and physical characteristics), as well as the of uncontaminated ground water, as well as the types and levels of contaminants in ground water across the site. b. Specific Data Needs . The monitoring program provides the specific ground water quality data needed for resource management and regulatory compliance. Specific ground water quality data is needed . Specific ground water quality data is neededfor planning, designing, and operating facilities related to site missions, including environmental protection and pollution prevention activities, as well as activities, as well as demonstratingdemonstrating compliance with regulatory requirements, and on-going assessment of performance of waste management and disposal units performance. c. Scope of Site-Wide Monitoring . The monitoring program should document includes a description of the current numbers of wells, numbers of number of samples per well per year, number of number of analyses per sample, , etc., and should provide a quantitative basis for estimating future modifications to the site-wide network, including a schedule for monitoring well replacement and abandonment. d. Purpose and Design of Monitoring Network . The monitoring program defines the purpose((s)) for monitoring the ground water,, and the the design of network((s)) related to each purpose. The monitoring program is reviewed regularly to ensure that the monitoring network(s) adequately meets address these purposes. e. Data Management . The monitoring program is capable ofassures that the users are getting the right data, enough data, adequate quality data, and not getting superfluous data. Historic data are retained and are retrievable for future use. f. Ensuring Efficiency and Cost Effectiveness . The monitoring program provides the minimum necessary ground water data at the appropriate quality at the lowest cost. The monitoring program includes a method for demonstrating that costs are justified. g. Utility of the Monitoring Data . The monitoring program provides data that meets the needs of the users. The monitoring program provides data that meets the needs of the users. A process is developed to enassure that the monitoring data satisfies the users’ needs and is being used effectively by the users. h. Continuous Improvement of Existing Monitoring Programs . Monitoring methods that reduce the costs of the monitoring program without reducing the amount or quality of the data are regularly being investigated and adopted, where appropriate., where appropriate. i. Alternative Monitoring Methods . Alternatives to conventional monitoring methods that will provide adequate data for meeting the purposes of the monitoring program purposes are regularly being investigated and adopted, where appropriate, where appropriate. j. Analysis of Trends . The monitoring program includes analyses of trends in ground water quality, across all areas of all areas of the site. Each site’s analyses allow similar review of long-term trends collectively at all DOE sites. Summarized data on the size, scope, and results of the site-wide ground water monitoring program should be easily obtainable from the site’s data management system, and should be included in the Aannual Ssite Eenvironmental Rreport in a manner consistent with EH-4annual guidance prepared by the Office of Environment, Safety and Health, to allow consistent Department-wide analyses of program the performance. of the program. 7. SURVEILLANCE MONITORING PROGRAM FUNDING . “Ensure site annual budgetary processes include the funding and resources needed to implement this Order” “Conduct environmental monitoring to detect, characterize, and respond to releases from DOE activities” “Ensure the analytical work supporting environmental monitoring is implemented using A consistent system for data collection and analysis A valid and consistent approach for sampling and analysis An integrated sampling approach to avoid duplication” Ground water surveillance monitoring is an activity that is an activity that will be conducted at many DOE sites for many years. Where wastes remain after all other site all other site operational activities are have been completed and the the site is closed due toafter active completion of environmental restoration has been completed, and even where no releases from any disposal units have occurred, there will continue to be a need for ground water surveillance monitoring. This is especially true where the area of the site that is dedicated the area of the site that is dedicated to waste management is in is in close proximity proximity to lands and facilities that are no longer under any formal any use restrictionss. Industrial, residential, or recreational land use at former DOE sites may be subject to future threats releases if long-term surveillance monitoring is not faithfully conducted where wastes or contaminated areased areas remains. Each DOE site and each DOE each DOE program that is associated with a DOE site that is associated with the DOE site mustshould request sufficient resources in the annual budgetary process to support the site-wide surveillance monitoring network. Annual budgets should be prepared to include a specific request for funding and staffing of the site-wide program as a line item, recognizing the continued long-term importance of the network in meeting Order DOEDOE O 450.1 requirements and ensuring effective environmental stewardship. If DOE program and site-wide budgets do not typically address environmental monitoring as a specific budgetary item, the possibility exists that a site-wide surveillance monitoring program may not be adequately funded. Consistent with an integrated ground water monitoring program is the need for an integrated site-wide funding source for ground water monitoring program activities program activities. The site-wide needs for well construction/abandonment, sampling and analysis, data management and reporting, QA/QC, etc., should be addressed in a composite budget request, rather than in a fragmented or piecemeal fashion. Each DOE program office that is responsible for any facility, program, or activity at a specific DOE site that may impact ground water resources should provide its share of the cost for fully funding the integrated site-wide surveillance monitoring program. This is important from a corporate, as well as and a site-wide DOE management perspective,, since an integrated budget identifies the full costs associated with operating a site-wide ground water monitoring program. Management can determine the full cost of sampling and analyzing ground water, as well as and demonstrating the cost-effectiveness of monitoring system improvements with a single budgetary amount for the full site-wide program. 8. REFERENCES :. a. 10 CFR PR, Part 830,. Nuclear Safety Management. b. DOE 2003. DOE O 450.1., Environmental Protection Program, (dated 1/-15/-03). (online at http://www.directives.doe.gov/pdfs/doe/doetext/neword/450/o4501.html). c. DOE 2001. DOE O 435.1. , Radioactive Waste Management (, dated 8/-28/-01). (online at http://www.directives.doe.gov/pdfs/doe/doetext/neword/435/o4351c1.html http://www.directives.doe.gov/pdfs/doe/doetext/neword/435/o4351c1.pdf). (http://www.directives.doe.gov/pdfs/doc/doetext/neword/435/o4351c1.html) d. DOE 2001a. DOE M 435.1-1., Radioactive Waste Management Manual (, dated 6/19/-01). (online at http://www.directives.doe.gov/pdfs/doce/doetext/neword/435/m4351-1c1.html). e. DOE 1999. DOE G 435.1-1., Chapter 4. , Low-Level Waste Requirements (, dated 7/-9/-99). (online at http://www.directives.doe.gov/pdfs/doec/doetext/neword/435/g4351-1ch4.html). f. DOE 1993. DOE O 5400.5., Radiation Protection of the Public and the Environment (, dated 1/7/-93) (online at http://www.directives.doe.gov/pdfs/doec/doetext/oldord-/5400/o54005c2.html) g. DOE 1991. DOE/-EH-0173T. Environmental Regulatory Guide for Radiological Effluent Monitoring and Environmental Surveillance (, dated 1/January 1991). (online at http://tis.eh.doe.gov/oepa/guidance/aea/effluent/eh0173t.pdf). h. EPA-600-R-00-007, EPA 2000. Data Quality Objectives Process for Hazardous Waste Site Investigations. EPA/600/R-00/007. January 2000. (online at http://www.epa.gov/quality1/qs-docs/g4hw-final.pdf). DISTRIBUTION: INITIATED BY: All DOE Organizations Office of Environment, Safety and Health DOE G 450.1-6 i (and ii) DRAFT XX-XX-04 iv DOE G 450.1-6 DRAFT XX-XX-04 DOE G 450.1-6 iii (and ii) DRAFT XX-XX-04 18 DOE G 450.1-6 DRAFT XX-XX-04 DOE G 450.1-6 17 DRAFT XX-XX-04 DOE G 450.1-6 1 DRAFT XX-XX-04