Appendix H
Features of a Good Monitoring Program

Data collection and the interpretation and analysis of those data are inextricably linked. It is this linkage that places specific requirements on the data collection process to produce data needed to support decision making. A well-developed technical literature has supported the development of guidance for monitoring. This guidance is found in federal agency documents; particularly good examples specific to environmental monitoring are provided by the U.S. Environmental Protection Agency (EPA) in its Quality Assurance Program (QAP). The Department of Energy (DOE), as part of an intergovernmental working group, has itself produced uniform federal guidance for quality assurance programs that are applicable to environmental monitoring in the Uniform Federal Policy for Quality Assurance Project Plans (IDQTF, 2005).

As used in this context, a quality assurance project plan (QAPP) for a monitoring program goes far beyond review and record keeping, or even the protocols for handling of samples and continuity of possession associated with quality control. Quality assurance here includes ensuring that the goals of the monitoring program are well defined and clearly articulated, that data collection strategies and methods are well matched to the goals, and that the data collected are in a form that enables them to be used as information for analysis (see Sidebar H-1).

The committee has identified seven features of a good monitoring program that are worth noting. A good monitoring program (1) is goal oriented; (2) has an integrated vision of monitoring for the overall site; (3) seeks the relevant information in the right places; (4) observes the environment (both natural and constructed) and the dynamics that affect processes of interest; (5) provides early warning to enable intervention if necessary; (6) is subjected to review on a regular basis and adapts to changing circumstances; and (7) archives data in a durable and accessible form. Each of these features is discussed below.

GOAL ORIENTED

A critical element of a good monitoring program is the identification and clear statement of the objectives that are used to guide monitoring design. A good monitoring program is designed to answer specific questions that underlie the purpose of the program (site characterization, emissions from operations, and so forth. Furthermore, data from one stage of monitoring can be helpful in designing the next stage, provide a useful historical base and supply information to support other efforts (e.g., performance assessment). As noted elsewhere in this report, there are several regulatory drivers for monitoring disposal sites and surrounding areas at Hanford, Idaho Falls, and Savannah: namely, Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA); Resource Conservation and Recovery Act (RCRA); specific elements of the Federal Facility Agreements; and the performance objectives in 10 CFR 61. These regulatory drivers are considered in formulating the goals of the monitoring programs at the sites.

AN INTEGRATED VISION OF MONITORING FOR THE OVERALL SITE

Despite the varied goals and methods used for monitoring different facilities, every environmental monitoring activity at a site contributes data that can be used to some extent to improve the understanding environmental and engineered systems at the site. If monitoring of disposal facilities is designed in the context of monitoring adjacent facilities and the overall, site-wide monitoring program, it is easier to gain useful information from the monitoring data. Even better, if DOE can work with regulators to develop an integrated vision of monitoring at the site, fitting together the various monitoring goals, the monitoring program can operate more efficiently and maximize the information gained from monitoring data.



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Tank Waste Retrieval, Processing, and On-Site Disposal at Three Department of Energy Sites: Final Report Appendix H Features of a Good Monitoring Program Data collection and the interpretation and analysis of those data are inextricably linked. It is this linkage that places specific requirements on the data collection process to produce data needed to support decision making. A well-developed technical literature has supported the development of guidance for monitoring. This guidance is found in federal agency documents; particularly good examples specific to environmental monitoring are provided by the U.S. Environmental Protection Agency (EPA) in its Quality Assurance Program (QAP). The Department of Energy (DOE), as part of an intergovernmental working group, has itself produced uniform federal guidance for quality assurance programs that are applicable to environmental monitoring in the Uniform Federal Policy for Quality Assurance Project Plans (IDQTF, 2005). As used in this context, a quality assurance project plan (QAPP) for a monitoring program goes far beyond review and record keeping, or even the protocols for handling of samples and continuity of possession associated with quality control. Quality assurance here includes ensuring that the goals of the monitoring program are well defined and clearly articulated, that data collection strategies and methods are well matched to the goals, and that the data collected are in a form that enables them to be used as information for analysis (see Sidebar H-1). The committee has identified seven features of a good monitoring program that are worth noting. A good monitoring program (1) is goal oriented; (2) has an integrated vision of monitoring for the overall site; (3) seeks the relevant information in the right places; (4) observes the environment (both natural and constructed) and the dynamics that affect processes of interest; (5) provides early warning to enable intervention if necessary; (6) is subjected to review on a regular basis and adapts to changing circumstances; and (7) archives data in a durable and accessible form. Each of these features is discussed below. GOAL ORIENTED A critical element of a good monitoring program is the identification and clear statement of the objectives that are used to guide monitoring design. A good monitoring program is designed to answer specific questions that underlie the purpose of the program (site characterization, emissions from operations, and so forth. Furthermore, data from one stage of monitoring can be helpful in designing the next stage, provide a useful historical base and supply information to support other efforts (e.g., performance assessment). As noted elsewhere in this report, there are several regulatory drivers for monitoring disposal sites and surrounding areas at Hanford, Idaho Falls, and Savannah: namely, Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA); Resource Conservation and Recovery Act (RCRA); specific elements of the Federal Facility Agreements; and the performance objectives in 10 CFR 61. These regulatory drivers are considered in formulating the goals of the monitoring programs at the sites. AN INTEGRATED VISION OF MONITORING FOR THE OVERALL SITE Despite the varied goals and methods used for monitoring different facilities, every environmental monitoring activity at a site contributes data that can be used to some extent to improve the understanding environmental and engineered systems at the site. If monitoring of disposal facilities is designed in the context of monitoring adjacent facilities and the overall, site-wide monitoring program, it is easier to gain useful information from the monitoring data. Even better, if DOE can work with regulators to develop an integrated vision of monitoring at the site, fitting together the various monitoring goals, the monitoring program can operate more efficiently and maximize the information gained from monitoring data.

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Tank Waste Retrieval, Processing, and On-Site Disposal at Three Department of Energy Sites: Final Report SIDEBAR H-1 Quality Assurance Project Plan As stated in the uniform federal policy for quality assurance project plans (IDQTF, 2005): A QAPP is a formal document describing in comprehensive detail the necessary quality assurance (QA), quality control (QC), and other technical activities that must be implemented to ensure that the results of the work performed will satisfy the stated performance criteria. A QAPP presents the steps that should be taken to ensure that environmental data collected are of the correct type and quality required for a specific decision or use. It presents an organized and systematic description of the ways in which QA and QC should be applied to the collection and use of environmental data. A QAPP integrates technical and quality control aspects of a project throughout its life cycle, including planning, implementation, assessment, and corrective actions. A well-implemented QAPP is well documented and has a clearly defined objective that drives data collection. The type and quality of the data collection are judged based on how well they support the objective or decision. In conducting any type of analysis system behavior due to various stresses, it is necessary to recognize that the different components of the hydrologic system (surface and subsurface) are coupled and are in dynamic interaction. At a specific site however, these interconnections and the coupling between the different components or units may not be significant. In these situations, some of the units may be relatively isolated. For example, DOE’s Savannah River Site has three distinct watersheds, so the surface hydrology is distinct. Even though watersheds that contribute to surface flow are isolated, the groundwater flow within these distinct watersheds may be interconnected depending on the geology and the hydraulic head distribution. Because of possible interconnections, complex subsurface flow patterns (e.g., due to perched water), and limited knowledge of geologic heterogeneity and geochemical behavior, attempts to develop an understanding of a complete, integrated site-wide behavior of the hydrologic regime can prove difficult. In general, it is believed that at most of the large DOE sites the possible pathways of contaminant transport off-site are relatively well understood. An integrated vision for site monitoring requires that program managers hypothesize how the hydrologic regime works even though some of the internal connections may not yet be fully understood. At the same time however, the committee notes that lessons learned about one geo-hydrologic unit may be useful in understanding another unit, even if the units are isolated from each other. RELEVANT INFORMATION IN THE RIGHT PLACES To identify what to look for and where to look, a good monitoring program is connected with a conceptual model of the site and, in the context of this study, the performance assessment program in an iterative approach that improves both activities. Historical monitoring data provide the basis for the performance assessment design (see Chapter VII). Performance assessment can then be used to screen contaminants and locations to focus the monitoring program on the most important contaminants and the likely pathways for contaminant migration. The extent to which the set of contaminants and locations can be narrowed depends on the extent of knowledge and understanding of the environmental surrounding, including the disposal site, which argues for site characterization that is continually improved by new data. Although it is appropriate to concentrate the greatest efforts on the media that are most important to meeting the goals and objectives of the program, the committee believes that a good monitoring program would consider all environmental media. This is because good monitoring is used to detect the unexpected or to provide assurance that a concentration of effort is appropriate. OBSERVATION OF THE ENVIRONMENT (BOTH NATURAL AND CONSTRUCTED) AND THE DYNAMICS THAT AFFECT PROCESSES OF INTEREST A good monitoring program is based on current understanding of the characteristics and dynamics of the site environment and how those dynamics are altered by site activities, and it is designed to fill gaps in the data and to investigate anomalies. This understanding can be obtained by the integration of data collected on the site over time from a wide range of monitoring activities, whether for process analysis, surveillance, general environmental monitoring, or compliance. The available background data help identify processes controlling the movement and impact of contaminants. As noted above, a good monitoring program that is connected with the performance assessment program in an

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Tank Waste Retrieval, Processing, and On-Site Disposal at Three Department of Energy Sites: Final Report iterative approach improves both monitoring effectiveness and the validity of models used to predict contaminant movement. The monitoring program will fill data gaps pertaining to environmental understanding and the dynamics effecting processes of interest. It will also help to refine the baseline understanding over time, from initial site characterization through closure and beyond (if necessary) and provide data to test hypotheses about future environmental conditions and dynamics at a site. The value of monitoring data is measured not in the amount collected but the utility of the data. In monitoring programs where wastes present a clear threat to the environment and public health, there is a need for programs to produce data that can be processed and used in a timely decision-making process that will support actions to minimize immediate threats to the environment and public health. PROVIDES EARLY WARNING TO ENABLE INTERVENTION A buffer zone is the region that lies between a facility and a location at which compliance is assessed. The availability of monitoring points in the buffer zone is related to early detection of the migration of hazards. A buffer zone provides a safety margin that allows contaminant detection and corresponding mitigation to proceed while contaminants remain on-site. To enable timely detection of contaminants, a monitoring program may have to locate observation points well before the point of compliance. Further, the need for buffer zones also requires careful assessment of the possible means of any threat of migration off-site and how that threat may change over time and distance with potential change in wastes in the natural environment. To be effective in this role as sentinel, the monitoring program has to have a clear path for the use of monitoring data to support identification of the necessary action and a plan to mitigate the problem before contaminants or radioactive wastes can leave the site. REVIEW ON A REGULAR BASIS TO ADAPT TO CHANGING CIRCUMSTANCES A good monitoring program has a formal mechanism for regular review relative to goals and to changes in the environment. The committee recognizes that just as conditions in the environment may be expected to change over time, the relationship between the environment and wastes in disposal sites may change. Further, the performance of the monitoring system, the technology available for monitoring, or the goals of the monitoring program may change. As a result, monitoring plans may have to adapt to new conditions (e.g., observation locations may need to be relocated) to provide proper surveillance of wastes and data that can be used for rapid assessment and mitigation response to threats that disposal sites pose to the environment and public health. DATA FROM DIFFERENT SOURCES ARCHIVED IN A DURABLE AND ACCESSIBLE FORM A monitoring program observes the environment and collects data, but those data do not inform decisions or understanding unless they are recorded, accessible, and understood. It is particularly important to pay attention to metadata, the detailed description of data collection and analysis methodologies, to ensure that future interpretations of archived data are comprehensive and compatible. A good monitoring program, therefore, stores data in a form that is readily understood and accessed with a full metadata complement. In addition, data collected by a monitoring program not only are products of the program but also essential elements of the overall monitoring effort. Further, the data are a historical record of environmental conditions and behavior essential for the analysis of site dynamics. The historical record provides a context for new data and a basis for review and improvement of the program, and so must endure for a long time (decades and perhaps centuries) if it is to continue to support the long-term requirements of site management.