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

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

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

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

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

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

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

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

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

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

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

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

13. Thank You! Questions?