Data Quality Objectives at Resource and
Recovery Act
Treatment,
Storage and Disposal Facilities (DQOs at RCRA TSDFs)
David Gossman
Gossman Consulting, Inc.
Presented
at the Hazardous Waste Combustors specialty Conference, Dallas, TX,
September 22-24, 1999.
ABSTRACT
EPA has provided a number of sources for guidance on the establishment of DQOs. This guidance is generally for site investigation and remediation projects. With minor modifications, the guidance is useful for establishing DQOs at commercial RCRA TSDFs. The process can help to reduce laboratory burdens as well as identify specific parameters where greater effort may be needed to maintain compliance. Two examples of how the process can be used are provided.
INTRODUCTION
EPA has provided a number of documents that provide guidance on the establishment of DQOs,. The Department of Energy has provided a summary of EPA guidance at its website <http://etd.pnl.gov:7080/DQO/steps.htm>. ASTM has developed a standard, D5792 - Standard Practice For Generation of Environmental Data Related to Waste Management Activities: Development of Data Quality Objectives. Generally, those documents are written with an orientation toward cleanup projects. EPA, in SW-846, requires RCRA waste analysis programs to also develop DQOs. The following incorporates minor modifications into existing EPA guidance so that this process can more easily be used by commercial RCRA facilities in order to establish DQOs for laboratory determinations. Two examples of DQOs for commonly performed laboratory determinations at RCRA BIF facilities are provided.
WHY DQOs
Beyond the quick answer that it is an EPA requirement, the process of developing the DQO and the resulting DQO for use in a QA/QC plan can provide significant operational and financial benefits to a commercial RCRA facility. The DQO process develops quality control standards for the laboratory that provide needed data with a tolerable degree of uncertainty. Since the maintenance of data quality can be an enormous cost, such a program can result in significant cost savings. Furthermore, the DQO process provides defensible justification of laboratory data collection activities, thus minimizing liabilities.
STEPS IN THE PROCESS
Step One: Problem Statement
The purpose of this step is to clearly define the problem that requires
environmental data so that the focus of the effort will be clear and
unambiguous.
Potential Activities
The purpose of this step is to define the decision that will be made using data to address the issue.
Potential Activities
The purpose of this step is to identify the informational inputs that will be required to [make the decision], and to determine which inputs require analytical data.
Potential Activities
The purpose of this step is to specify the [temporal circumstances] that are covered by the decision.
Potential Activities
The purpose of this step is to integrate the outputs from previous steps into a single statement that describes the logical basis for choosing among alternative actions.
Potential Activities
The purpose of this step is to specify the decision maker's acceptable limits on decision errors, which are used to establish appropriate performance goals for limiting uncertainty in the data.
Potential Activities
The purpose of this step is to identify the most resource-effective analysis design for generating data that are expected to satisfy the DQOs.
Potential Activities
EXAMPLE 1 - DQO FOR HEAT CONTENT DETERMINATIONS IN HAZARDOUS WASTE FUEL RECEIVED AT COMMERCIAL RCRA HAZARDOUS WASTE BURNING CEMENT FACILITIES
Problem Statement
RCRA rules and some state/local permits prohibit the use of wastes
with <5000 BTU/lb as fuel for RCRA permitted Boilers and Industrial
Furnaces (BIFs). Furthermore, the cement plant needs information on the
heat content of the waste fuels to determine appropriate feed rates.
Decision Statement
The shipment waste testing program (part of the facility Waste Analysis
Plan) seeks to provide information to aid in the prevention of receipt
of shipments with less than the needed heat content. The cement plant
needs
heat content information in order to set fuel feed rates (heat input).
Inputs to the Decision
In addition to information and certifications from the generator, a
5000 BTU/lb threshold determination of heat content in each shipment is
needed to either accept or reject the shipment. In order to set fuel
feed
rates (heat input), the cement kiln operator needs a quantitative
evaluation
of the waste fuel heat content.
Decision Boundaries
A separate determination and decision is needed for each shipment.
This decision generally needs to be made within one hour of the arrival
of the shipment on site. For these reasons, the analytical
determination
needs to be performed on site.
Decision Rule
If the measured heat content is less than 5000 BTU/lb, the shipment
will be rejected. Heat content of waste fuel will be used to modify the
input rate of other fuels appropriately.
Tolerable Limits on Decision Errors
There should be no greater than a 5% probability that any individual
shipment is received with a heat content of <5000 BTU/lb. The kiln
operator
should be able to use heat content measurements of the waste fuel to
adjust
other fuel rates to within 2% of target levels.
Optimize the Design
In order to meet the tolerable limits on decision errors, the following
procedures and QC requirements are needed:
Problem Statement
The use of PCBs or PCB contaminated material as a waste fuel in cement
kiln fuel programs is a violation of 40 CFR 761.60 as well as local
permits
and regulations. Historically, these materials have occasionally been
found
in wastes received for use as fuels without prior notification or
manifesting.
Decision Statement
The shipment waste testing program (part of the facility Waste Analysis
Plan) seeks to provide information to aid in the prevention of receipt
of shipments contaminated with PCBs.
Inputs to the Decision
In addition to information and certifications from the generator, a
50 ppm threshold determination of PCB content in each shipment is
needed
to either accept or reject the shipment. The 50 ppm threshold is based
on regulating criterion establishing the level at which a waste is
considered
PCB contaminated.
Decision Boundaries
A separate determination and decision is needed for each shipment.
This decision generally needs to be made within one hour of the arrival
of the shipment on site. For these reasons, the analytical
determination
needs to be performed on site.
Decision Rule
If the measured concentration of PCBs is 50 ppm or greater, then the
shipment will be rejected.
Tolerable Limits on Decision Errors
There should be no greater than a 5% probability that any individual
shipment is received with a PCB concentration greater than or equal to
50 ppm.
Optimize the Design
In order to meet the tolerable limits on decision errors, the following
procedures and QC requirements are needed: