ML22106A003

Addendum 2 to the Supplemental Sampling and Analysis Plan for the Ettp: Reference for the Kairos Hermes CP Application

ML22106A003
Person / Time
Site:	Hermes
Issue date:	07/31/2021
From:	UCOR, an Amentum-led Partnership with Jacobs
To:	Office of Nuclear Material Safety and Safeguards, US Dept of Energy, Office of Environmental Management
Dozier T
References
DE-SC-0004645 DOE/OR/01-2749&D1/A2/R2
Download: ML22106A003 (95)

Text

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DOE/OR/01-2749&D1/A2/R2 Addendum 2 to the Supplemental Sampling and Analysis Plan for the East Tennessee Technology Park Sitewide Residual Contamination Remedial Investigation K-31/K-33 Area Oak Ridge, Tennessee This document has been reviewed and confirmed to be UNCLASSIFIED and contains no UCNI.

Name: Dave Lannom Date: 07/07/2021 UCOR eDC/RO ID: 11383

E.0524.027.0212 DOE/OR/01-2749&D1/A2/R2 Addendum 2 to the Supplemental Sampling and Analysis Plan for the East Tennessee Technology Park Sitewide Residual Contamination Remedial Investigation K-31/K-33 Area Oak Ridge, Tennessee Date IssuedJuly 2021 Prepared for the U.S. Department of Energy Office of Environmental Management UCOR LLC under contract DE-SC-0004645

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CONTENTS FIGURES ...................................................................................................................................................... v TABLES ..................................................................................................................................................... vii ACRONYMS ............................................................................................................................................... ix

1. INTRODUCTION ............................................................................................................................... 1-1

2. SITE HISTORY .................................................................................................................................. 2-1

3. DATA QUALITY OBJECTIVES ....................................................................................................... 3-1 3.1 CONCEPTUAL SITE MODEL .................................................................................................. 3-1 3.1.1 Sources and Release Mechanisms ................................................................................... 3-1 3.1.2 Chemicals of Concern ...................................................................................................... 3-2 3.1.3 Fate and Transport Pathways ........................................................................................... 3-5 3.2 DATA QUALITY OBJECTIVES FOR THE SUPPLEMENTAL SAMPLING ...................... 3-12

4. SAMPLING AND ANALYSIS APPROACH .................................................................................... 4-1 4.1 PROPOSED SAMPLING AND ANALYSIS ............................................................................. 4-1 4.1.1 Quarterly Sampling .......................................................................................................... 4-1 4.2 TEMPORARY PIEZOMETER INSTALLATION AND MONITORING ................................ 4-7 4.3 QUALITY CONTROL DUPLICATE SAMPLES.................................................................... 4-10 4.4 QUALITY CONTROL TRIP BLANK SAMPLES .................................................................. 4-10

5. SAMPLE COLLECTION METHOD ................................................................................................. 5-1 5.1 GROUNDWATER ...................................................................................................................... 5-1 5.1.1 Sampling of Wells ........................................................................................................... 5-1 5.1.2 Analytical Parameters ...................................................................................................... 5-1 5.1.3 Quality Control Duplicate Samples ................................................................................. 5-1 5.1.3.1 Quality Control Rinsate Blank Samples ............................................................. 5-1 5.1.3.2 Quality Control Trip Blank Samples .................................................................. 5-2

6. INVESTIGATION-DERIVED WASTE............................................................................................. 6-1

7. REPORTS ........................................................................................................................................... 7-1

8. PROJECT SCHEDULE ...................................................................................................................... 8-1

9. REFERENCES .................................................................................................................................... 9-1 APPENDIX A. UNIFORM FEDERAL POLICY QAPP CHECKLIST .................................................. A-1 iii

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FIGURES Fig. 1.1. Location of the K-31/K-33 Area at ETTP. .................................................................................. 1-3 Fig. 2.1. Location of historical facilities and RCW lines and leak sites in the K-31/K-33 Area. .............. 2-5 Fig. 2.2. Aerial view of the K-312/K-33 Area, circa 2019. ....................................................................... 2-6 Fig. 3.1. Unconsolidated zone potentiometric surface in the K-31/K-33 Area, October 2017. ................. 3-7 Fig. 3.2. Bedrock potentiometric surface in the K-31/K-33 Area, October 2017. ..................................... 3-8 Fig. 3.3. Pre-construction topographic map from 1941 (USGS Elverton quadrangle map, 1941). ........... 3-9 Fig. 3.4. Topographic surface from LiDAR............................................................................................. 3-10 Fig. 3.5. Storm drain network in the K-31/K-33 Area. ............................................................................ 3-11 Fig. 4.1. Proposed monitoring wells for additional sample collection in the K-31/K-33 Area. ................ 4-5 Fig. 4.2. Proposed temporary DPT piezometer locations. ......................................................................... 4-9 v

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TABLES Table 2.1. Timeline of ETTP Groundwater Investigations Addressing the K-31/K-33 Area.................... 2-2 Table 3.1. Summary statistics for 21 K-31/K-33 wells, unfiltered groundwater 2016-2020 .................... 3-4 Table 3.2. MCL exceedances in February-March 2020 groundwater samples in the K-31/K-33 Area ....................................................................................................................... 3-5 Table 3.3. Surface water analytical results exceeding water quality criteria from the K-31/K-33 Area storm drain sampling effort, 2018-2019 ...................................................... 3-6 Table 3.4. DQOs for the K-31/K-33 Area groundwater evaluation......................................................... 3-12 Table 3.5. Sampling needs evaluation ..................................................................................................... 3-13 Table 4.1. K-31/K-33 Area groundwater sampling results summary and wells proposed for further sampling................................................................................................................................... 4-3 Table 4.2. Summary of well conditions and wells with dedicated pumps for micro-purge, low-flow sample collection...................................................................................................... 4-6 Table 4.3. Proposed analyte list for the K-31/K-33 Area .......................................................................... 4-6 Table 4.4. Proposed PFOS/PFAS Parameters to be Reported ................................................................... 4-7 Table 5.1. Detailed analyte list, analytical methods, and reporting requirements for K-31/K-33 groundwater samples a ............................................................................................................. 5-3 Table 6.1. Revised waste summary for K-31/K-33 groundwater sampling activities ............................... 6-1 vii

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ACRONYMS ARAR applicable or relevant and appropriate requirement ASTM American Society for Testing and Materials bgs below ground surface CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980 Cr+6 hexavalent chromium CSM conceptual site model DO dissolved oxygen DOE U.S. Department of Energy DPT direct push technology DQO data quality objective EPA U.S. Environmental Protection Agency ETTP East Tennessee Technology Park FS Feasibility Study Kd partition coefficient LiDAR light detection and ranging M-K Mann-Kendall MCL maximum contaminant level MNA Monitored Natural Attenuation NPDES National Pollutant Discharge Elimination System ORP oxidation-reduction potential ORR Oak Ridge Reservation PFAS per- and polyfluoroalkyl substances PFOA perfluorooctanoic acid PFOS perfluorooctane sulfonic acid PRG Preliminary Remediation Goal QAPP Quality Assurance Project Plan QC quality control RCW Recirculating Cooling Water RI Remedial Investigation RIWP Remedial Investigation Work Plan RSE Remedial Site Evaluation SAP Sampling and Analysis Plan TCE trichloroethene TDEC Tennessee Department of Environment and Conservation VOC volatile organic compound WRRP Water Resources Restoration Program ix

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1. INTRODUCTION The K-31/K-33 Area is located in the northwestern portion of the East Tennessee Technology Park (ETTP) on the U.S. Department of Energy (DOE) Oak Ridge Reservation (ORR) (Fig. 1.1). In 2017, DOE, the U.S. Environmental Protection Agency (EPA), and the Tennessee Department of Environment and Conservation (TDEC) agreed to pursue a separate groundwater decision for this area under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA).

In May 2019, DOE submitted the K-31/K-33 Area Groundwater Remedial Site Evaluation Report for the East Tennessee Technology Park, Oak Ridge, Tennessee (DOE/OR/01-2765&D2; RSE). In response to the D2 report, EPA recommended further monitoring to establish a longer-term reduction in contaminant concentrations coupled with trend analysis to demonstrate an endpoint for groundwater monitoring. TDEC recommended that DOE should develop a more robust characterization of the site to sufficiently define and explain the identified maximum contaminant level (MCL) exceedances.

A meeting was held on May 29, 2019, between DOE, EPA, and TDEC project managers during which an agreement was reached to sample all existing groundwater monitoring wells at the K-31/K-33 Area. DOE developed an Addendum to the Supplemental Sampling and Analysis Plan for the East Tennessee Technology Park Sitewide Residual Contamination Remedial Investigation, Oak Ridge, Tennessee (DOE/OR/01-2749&D1/A1) which was issued in July 2019.

DOE presented the results of the additional sampling in a series of project team meetings in the summer of 2020, at which time DOE proposed moving forward with a Monitored Natural Attenuation (MNA) decision for the site. EPA and TDEC indicated that an MNA decision, if found to be appropriate, would require specific trend data to shows that the contamination at K-31/K-33 was not increasing. This second addendum to the Supplemental Sampling and Analysis Plan (SAP) has been developed to address the additional sampling that will be used to develop a Remedial Investigation/Feasibility Study (RI/FS) and propose a final groundwater decision for the site.

Predecessor work plan, QAPP, QAPP Checklist documents, which help guide the work completed in this SAP Addendum include the following:

• DOE/OR/01-1612/V1&D2. East Tennessee Technology Park Site-Wide Remedial Investigation Work Plan, Volume 1, Main Text

• DOE/OR/01-2154&D2. East Tennessee Technology Park Site-Wide Residual Contamination Remedial Investigation Work Plan, Oak Ridge, Tennessee

• DOE/OR/01-2154&D2/A1/R1. Addendum to the East Tennessee Technology Park Site-Wide Residual Contamination Remedial Investigation Work Plan, Oak Ridge, Tennessee

• DOE/OR/01-2224&D4. Remedial Design Report/Remedial Action Work Plan for Zone 2 Soils, Slabs, and Subsurface Structures, East Tennessee Technology Park, Oak Ridge, Tennessee

• DOE/OR/01-2749&D1/A1. Addendum to the Supplemental Sampling and Analysis Plan for the East Tennessee Technology Park Sitewide Residual Contamination Remedial Investigation, Oak Ridge, Tennessee

• UCOR-4587/R6. Sampling and Analysis Plan for the Water Resources Restoration Program for Fiscal Year 2021 Oak Ridge Reservation, Oak Ridge, Tennessee 1-1

• UCOR-4049. Quality Assurance Project Plan for the Water Resources Restoration Program, U.S. Department of Energy, Oak Ridge Reservation, Oak Ridge, Tennessee

• UCOR-4160. Data Management Implementation Plan for the Water Resources Restoration Program, Oak Ridge, Tennessee 1-2

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2. SITE HISTORY The site history of the K-31/K-33 Area is described fully in the Final Sitewide Remedial Investigation and Feasibility Study for the East Tennessee Technology Park, Oak Ridge, Tennessee (DOE/OR-01-2279&D3).

Key former process and support buildings and structures as well as existing groundwater monitoring wells are show on Figs. 2.1 and 2.2.

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The K-33 building demolition was completed in 2011, and removal of the K-33 concrete slab was completed in 2012. As part of the removal action, electrical conduit manholes were filled with concrete and floor drains removed. Hot spot areas of soil and piping were removed based on radiological surveys. These actions are described in the Phased Construction Completion Report for Exposure Units Z2-04 and Z2-05 in Zone 2, East Tennessee Technology Park, Oak Ridge, Tennessee (DOE/OR/01-2590&D1; EU Z2-04/-05 PCCR).

The K-31 building demolition and slab removal were completed in 2015. No soil remedial action was necessary for the K-31 building (Fiscal Year 2015 Phased Construction Completion Report for Exposure Unit Z2-06 in Zone 2, East Tennessee Technology Park, Oak Ridge, Tennessee, (DOE/OR/01-2699&D2);

however, a metal-lined, gravel-filled structure located near the southeast corner of the building footprint was found to have elevated radioactivity and the structure was removed.

The K-903 slab consisted of reinforced concrete that previously housed the Building K-33 Compactor Facility. Originally left in place, the K-903 slab was radiologically contaminated, potentially by the Building K-33 tie-line size-reduction activities that were performed using the K-903 slab. Due to the radiological contamination, the K-903 slab was removed in the fall of 2015.

Other completed remedial actions in the K-31/K-33 Area included demolition of the K-1206-F Fire Water Tank and removal of the sludge from the cooling tower basins. Demolition of the K-1206-F Fire Water Tank, located in the southeast corner of the area, was conducted in August of 2013 through a controlled explosive demolition. The 382-ft-tall water tank toppled into an empty field, and the metal from the tank was recycled. Paint chips dislodged during size reduction of the metal structure were collected, packaged, and disposed. Approximately 4 ft3 of lead-containing paint chips were collected following demolition and disposed of at an off-site Resource Conservation and Recovery Act of 1976 facility.

Demolition of the K-892-G/H and K-861 cooling tower basins was completed in 1997 and included the removal of sediment that had accumulated in the basins. The project consisted of the demolition of the cooling tower superstructure, removal of sediment from the basins, and demolition of the above-grade basins and auxiliary facilities. The sediment removal phase included dewatering of the removed material and disposal of over 3400 yd3 of sediment from the basins. The basin sediment was shipped to Utah for disposal due to the presence of low levels of radioactive contamination.

The former K-762 and K-792 switchyards were demolished in 1998, and demolition of the associated K-761 switchhouse was completed in 2016.

The Recirculating Cooling Water (RCW) system removed heat from the process coolant, which in turn removed the heat of compression from the process gas. The early corrosion inhibitors used in the RCW systems were phosphate compounds. These compounds were used in the RCW systems between 1944 and the late 1950s. The zinc/chromate/phosphate corrosion treatment came into use in the late 1950s. This treatment was a powdered mixture containing a chromate salt, a sulfate salt, and zinc sulfate. In 1983, the physical forms of these chemicals were changed to liquids; however, they were chemically identical to the 2-1

original powdered treatment. The chromate salt consisted of hexavalent chromium (Cr+6). The zinc/chromate/phosphate corrosion inhibitors were used until shutdown in 1985.

The K-31/K-33 Area has been transferred to the Community Reuse Organization of East Tennessee and a portion has subsequently been leased by Consolidated Nuclear Security, LLC for use as an equipment staging area in support of the Uranium Processing Facility at the National Nuclear Security Administration Y-12 facility (Fig. 2.2). The property transfer was completed in accordance with approved Covenant Deferral Requests under CERCLA.

Characterization and monitoring of groundwater quality and potential groundwater contaminant sources in the K-31/K-33 Area has been ongoing since 1989 as indicated in Table 2.1. Monitoring wells were installed along the boundary of the site and in proximity to RCW leak sites to monitor potential releases. Since inception of the monitoring efforts, DOE has reported low levels of mostly chromium, but also other sporadic metals, slightly above MCL levels. Efforts to get a final decision on the K-31/K-33 Area groundwater have been suspended several times since monitoring began.

Table 2.1. Timeline of ETTP Groundwater Investigations Addressing the K-31/K-33 Area Date Document Summary May 1996 Groundwater Remedial Site Evaluation

• Evaluated the K-31/K-33 Area, and Report (DOE/OR/01-1468&V1&D1) recommended that NFA be considered for this area.

September 1996 DQO Workshops for ETTP Sitewide

• Soil samples proposed to evaluate the Remedial Investigation K-31/K-33 RCW lines, but was decided to use the soil samples from the known leak site at K/27/K-29 Area to evaluate the impacts from the RCW lines.

• Grab groundwater sample proposed to evaluate RCW impacts to groundwater.

February 1998 EPA and TDEC Approval of ETTP Sitewide

• Summarized DQOs established for soils, RIWP (DOE/OR/01-1612/V1&D2) groundwater, surface water, sediment, and biota at ETTP.

• Outlines decision rules.

• Provides data input solutions.

January 1999 RI Report for the ETTP

• Presented the nature and extent of (DOE/OR/01-1778/V1&D1) contamination and the associated risk to human health and environment. Included the K-31/K-33 Area. Controlled industrial, uncontrolled industrial, recreational, and residential risk scenarios were evaluated. Only the residential scenario resulted in a groundwater risk for the K-31/K-33 Area.

• RI was not approved due to limited groundwater data and CSM understanding.

• Tri-party decision resulted in Zone 1 and 2 soil only action decisions.

June, July 1999 TDEC and EPA provided comments on RI

• Both TDEC and EPA identified many Report for ETTP deficiencies in the report, and the comments reflected a lack of information that adequately defines the nature and extent of contamination 2-2

Table 2.1. Timeline of ETTP Groundwater Investigations Addressing the K-31/K-33 Area (cont.)

Date Document Summary

• RI was not approved due to limited groundwater data and CSM understanding.

• Tri-party decision resulted in Zone 1 and 2 soil only action decisions.

• Project was suspended.

2001 WRRP identified ETTP wells to include in

• Added semi-annual sampling of the long-term monitoring network. UNW-043/BRW-030 and UNW-080/BRW-066 in K-31/K-33 Area.

December 2003, DQO workshops held for ETTP Sitewide

• DQO workshops determined that the RI January 2004, and Residual Contamination Remedial would be heavily dependent upon February 2004 Investigation existing data, with some additional data collection.

September 2004 ETTP Site-Wide Remedial Investigation

• No additional groundwater data was Work Plan (DOE/OR/01-2154&D2) issued. proposed for the K-31/K-33 Area.

June 2006 D1 version of the Final Sitewide Remedial

• Using existing wells in the Investigation and Feasibility Study for the K-31/K-33 Area, TCE and chromium ETTP (DOE/OR/01-2279&D1) issued. were the only constituents identified as exceeding MCLs.

• No risk identified for industrial worker in the K-31/K-33 Area.

May 2007 D2 version of the Final Sitewide Remedial Investigation and Feasibility Study for the ETTP (DOE/OR/01-2279&D2) issued.

November 2007 D3 version of the Final Sitewide Remedial

• This document was not approved.

Investigation and Feasibility Study for the ETTP (DOE/OR/01-2279&D3) issued.

June 2011 Addendum to ETTP Site-Wide Residual

• Proposes additional sampling in Zone 1.

Contamination RIWP No additional sampling was proposed for (DOE/OR/01-2154&D2/A1/R1) issued. the K-31/K-33 Area.

March 14 - 15, 2017 ETTP Sitewide Groundwater DQOs

• Second attempt to develop a Sitewide Workshop RI/FS.

June 2017 EPA and TDEC approve a Supplemental

• Based on DQO input. Addressed SAP for the East Tennessee Technology sampling from Zone 1 and Zone 2 areas.

Park Sitewide Residual Contamination No sampling in K-31/K-33 Area was Remedial Investigation Oak Ridge, proposed.

Tennessee (DOE/OR/01-2749&D1).

December 2017 DOE proposes separate decision for

• Parties identify two round of sampling K-31/K-33 Area and hosts a DQO meeting from 10 additional K-31/K-33 wells to determine any additional sampling needs

• Wells added to the sampling effort for planned Remedial Investigation (RI) conducted under DOE/OR/01-2749&D1.

January 2018, May, DOE collected samples from 10 additional

• Results are similar to previous results 2018 K-31/K-33 Area wells including low level detections above MCLs.

June 2018 DOE presents data results and parties agree to develop an RSE in place of the planned RI September 2018 DOE issues D1 version of the

• Summarized the available data and CSM K-31/K-33 Area Groundwater Remedial Site for the K-31/K-33 Area and Evaluation Report for the ETTP recommended NFA for groundwater in (DOE/OR/01-2765&D1). the K-31/K-33 Area.

November 2018 TDEC provides comments on the D1 version

• TDEC states they are not ready to make of the K-31/K-33 Area Groundwater a determination regarding a decision on 2-3

Table 2.1. Timeline of ETTP Groundwater Investigations Addressing the K-31/K-33 Area (cont.)

Date Document Summary Remedial Site Evaluation Report for the groundwater for the K-31/K-33 Area, ETTP (DOE/OR/01-2765&D1). and requests additional data to explain the MCL exceedances.

February 2019 EPA issues comments on the D1 version of

• EPA recommends further monitoring to the Remedial Site Evaluation Report for the establish a longer-term reduction in K-31/K-33 Area (DOE/OR/01-2765&D1) contaminant concentrations coupled with issued. trend analysis to demonstrate an endpoint for groundwater monitoring.

June 2019 TDEC issues comments on D2 version of

• TDEC stated that: Data are insufficient the Remedial Site Evaluation Report for the to obtain TDEC's support of a No K-31/K-33 Area (DOE/OR/01-2765&D2). Further Action decision (NFA) as a final groundwater decision as requested in this D2 Remedial Site Evaluation Report (RSE) for the K- 31 /K-33 area at this time due to the following concerns based on both quality and quantity of data:

July 2019 EPA issues comments on D2 version of the

• EPA stated that DOEs recommended Remedial Site Evaluation Report for the NFA decision across the K-31/K-33 Area K-31/K-33 Area (DOE/OR/01-2765&D2). is not an acceptable option.

• Declares K-31/K-33 RSE to be in Informal Dispute.

July 2019 Addendum to the Supplemental Sampling

• Describes groundwater sampling to be and Analysis Plan for the East Tennessee conducted in the K-31/K-33 Area in Technology Park Sitewide Residual response to EPA and TDEC comments Contamination Remedial Investigation on the D2 RSE for the K-31/K-33 Area.

Oak Ridge, Tennessee

• Samples to be collected during two (DOE/OR/01-2749&D1/A1) issued. sampling events conducted in summer 2019 (dry season) and late Winter/early spring 2020 (wet season).

October 2019 EPA and TDEC approve the Addendum to the Supplemental SAP for the ETTP Sitewide Residual Contamination Remedial Investigation (DOE/OR/01-2749&D1/A1).

May-July 2019; Dry season sampling and wet season February-March 2020 sampling of K-31/K-33 Area wells completed.

October 2020 CSM Update and additional data collection

• Initial input from TDEC and EPA is that discussions with tri-party project team. DOE additional data will be needed to show proposes moving forward with a Monitored statistically significant stable or Natural Attenuation (MNA) decision downward trends to support a MNA decision.

BRW = bedrock well NFA = No Further Action Cr = chromium RI = remedial investigation CSM = conceptual site model RSE = Remedial Site Evaluation DOE = U.S. Department of Energy TCE = trichloroethylene EPA = Environmental Protection Agency TDEC = Tennessee Department of Environment and ETTP = East Tennessee Technology Park Conservation MCL = Maximum Contaminant Level UNW = unconsolidated zone well MNA = Monitored Natural Attenuation VOC = volatile organic compound WRRP = Water Resources Restoration Program 2-4

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3. DATA QUALITY OBJECTIVES 3.1 CONCEPTUAL SITE MODEL The conceptual site model (CSM) for the K-31/K-33 Area is presented in the Final Sitewide RI/FS (DOE/OR/01-2279&D3) and will continue to be updated for the upcoming RI/FS. Drilling in the K-31/K-33 Area has shown that the overburden materials are varied and consist of a range of clay, silty clay, and clayey silt. Limestone gravel intermixed with the clay and clayey silt materials is present in many areas. Occasional thin sandy lenses are also present. Because these materials were largely of local origin, distinguishing fill material from native soils can be difficult. Although in general it may be expected that the reworked fill materials would be more permeable than the native soil materials around them, the fill was compacted substantially after placement to support the large process buildings; thus, making the fill less permeable than the native soils, which are likely to be more common along the perimeter of the area.

Although the geology of the ETTP is complex, it is less so in the K-31/K-33 Area, with the more consistently oriented bedding across the site. The K-31/K-33 Area is underlain by bedrock of the upper Knox Group, in the northern portion of the area, and the lower Chickamauga Group formations occupying the southern portion of the area. The Knox Group in the vicinity of the K-31/K-33 Area consists of the Kingsport Formation and the Mascot Dolomite (Lemiszki 1994), and the Chickamauga Group consists of the Pond Spring Formation, the Murfreesboro Limestone, the Ridley Limestone, the Lebanon Limestone, and the Carters Limestone. Structurally, these formations strike southwest to northeast, and dip to the southeast (Fig. 2.11). The angle of dip ranges from 20 to 50 degrees to the southeast based on measurements obtained from bedrock exposures along Poplar Creek (Lemiszki et al. 1995). Bedrock materials are primarily limestone with interbedded shale and dolostone with interbedded limestone. Zones of highly fractured bedrock were encountered in some bedrock boreholes, and three bedrock wells (BRW-030, BRW-031, and BRW-083) are completed in cavities in the underlying carbonate bedrock.

No chemicals, or radionuclides, were identified in the Zone 2 soil characterization efforts that suggested the presence of a source for the soil-to-groundwater transport pathway. Thus, the K-31/K-33 Area soils were granted approval for NFA to 10 ft bgs, and no actions to address the soil-to-groundwater pathway were deemed necessary.

Sampling of the K-31/K-33 monitoring wells with historical MCL exceedances began in 2017. In the past 10 years only antimony, arsenic, beryllium, chromium, lead, and nickel have exhibited concentrations that exceeded their respective MCLs. In addition, of the radiological parameters analyzed in groundwater, only gross alpha activity was detected above its MCL.

Following the installation of dedicated low-flow sampling pumps in all but two K-31/K-33 monitoring wells in 2019, there was a reduction in the number of metal and radiological constituents that exceed MCLs.

Historically, turbidity impacted the results of the unfiltered groundwater samples from the K-31/K-33 wells.

The turbidity data have shown that oftentimes there was an increase in the reported constituent concentrations corresponding to increased levels of turbidity in the samples. This was evidenced by the absence of MCL exceedances in the corresponding filtered samples.

Presented below is a summary of the key aspects of the K-31/K-33 Area CSM.

3.1.1 Sources and Release Mechanisms The primary historical contaminant release sources include:

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• The RCW system and firewater lines. Chromium is the primary chemical of concern associated with these historical releases. Surface release mechanisms included RCW line leaks, cooling tower basin seepage, cooling tower drift, and fire hydrant flushing. Subsurface release mechanisms included RCW line leaks and fire water line leaks with transport to underlying groundwater. Historical surface migration pathways included surface water runoff and storm drain discharge to Poplar Creek and the K-901 Pond. Subsurface migration pathways are via lateral transport in groundwater toward local discharge into Poplar Creek, the K-901 Pond, and the Clinch River.

• K-31/K-33 processing equipment and piping. Nickel was widely used in much of the process equipment. The larger process piping consisted of nickel-plated steel and the smaller piping was made of Monel, a nickel-copper alloy. Nickel, nickel-plated steel, and Monel were also used extensively in many components of the compressors, converters, and the barrier tubes. The presence of significant concentrations of nickel in the sediments deposited in the K-31/K-33 Area cooling tower basins, which were disposed prior to demolition of the cooling tower basins, indicates that leaching of nickel from the various cascade equipment and piping occurred, and was present in the RCW system. Thus, RCW line leaks, cooling tower basin leaks, and cooling tower drift would have contributed nickel to the surface and subsurface in the K-31/K-33 Area in the same way as described above.

• As noted in the post-demolition Zone 2 ROD sampling of the soils and infrastructure under the K-31/K-33 footprint, as well as targeted areas around the footprint, no chemicals, or radionuclides, were identified that would provide a continuing source for the soil-to-groundwater transport pathway.

This includes soils associated with the two electrical switchyards (K-762 and K-792) and other former facilities and infrastructure in the K-31/K-33 Area. Soil samples were collected in accordance with the requirements of the Remedial Design Report/Remedial Action Work Plan for Zone 2 Soils, Slabs, and Subsurface Structures, East Tennessee Technology Park, Oak Ridge, Tennessee (DOE/OR/01-2224&D4). The K-31/K-33 Area soils were granted approval for no further action to 10 ft below ground surface (bgs), and no actions to address the soil-to-groundwater pathway were deemed necessary (EU Z2-04/-05 PCCR) and the Environmental Baseline Survey Report for the Proposed Title Transfer of the Former K-31 Area at the East Tennessee Technology Park, Oak Ridge, Tennessee, (DOE/OR/01-2677).

3.1.2 Chemicals of Concern The human health risk to exposure to groundwater in the K-321/K-33 Area was addressed in the Baseline Human Health Risk Assessment (BHHRA) prepared for the Final Sitewide RI/FS for ETTP (DOE/OR/01-2279&D3). The BHHRA stated that groundwater in the K-31/K-33 Area had Few isolated wells with metal MCLs exceedance. Limited risk. Mostly uncontaminated below MCL levels. Since 2016, six metals have exhibited concentrations that exceeded their respective MCLs. Of the radiological parameters analyzed in groundwater, only gross alpha activity has been detected above its MCL. Table 3.1 provides summary statistics for metals and alpha activity for all groundwater samples collected since 2016 in the K-31/K-33 Area. Table 3.1 shows that chromium and nickel are the metals most often detected above an MCL. However, both of these metals have exceeded their MCL in less than 20% of the total samples collected since 2016. All other constituents (antimony, arsenic, beryllium, lead, and alpha activity) have exceeded MCLs in less than 5% of the groundwater samples collected since 2016.

Trichloroethene (TCE) is the only volatile organic compound (VOCs) that has been detected at concentrations exceeding the MCL in more than two samples since 1989. Historically, TCE has exceeded the MCL in six different monitoring wells (BRW-032, BRW-064, BRW-066, BRW-067, UNW-043, and UNW-078). However, TCE has not been detected at any of the K-31/K-33 wells at a concentration exceeding the MCL since 1998. Although a release of VOCs in the K-31/K-33 Area has not been identified 3-2

in historical records, use of TCE in cold traps used in the gaseous diffusion process is a potential source in the K-31/K-33 Area.

Table 3.2 summarizes the metals that have exceeded an MCL in the February and March 2020 groundwater samples from the K-31/K-33 monitoring wells. This table includes turbidity values associated with those samples, and it can be seen that turbidity impacts the results for unfiltered samples. Comparison of the filtered versus unfiltered results shows that in samples with high solids (UNW-039 and UNW-045), the metals concentrations are significantly higher in unfiltered results than dissolved results, suggesting a large mass remains bound to solids. In samples with low solids (e.g. BRW-031, UNW-043) chromium and nickel are very similar, and in these cases even the low dissolved concentrations are at or slightly above the MCL.

Based on requests from the regulatory agencies, a preliminary review of per- and polyfluoroalkyl substances/perfluorooctane sulfonic acid (PFAS/PFOS) use was conducted in April 2020 that focused on fire-fighting foams at the ETTP site. There were no indications of fire-fighting foams being used in the K-31/K-33 Area during this review effort. Further review conducted in July 2020 also identified no known operations in the K-31/K-33 Area that were tied to fire-fighting foams. In addition, limited historical operational reviews have been initiated to identify other potential PFAS/PFOS chemicals that may have been manufactured and used at ETTP in a physical form that could result in a release to the environment.

The initial reviews indicate there were other chemical PFAS/PFOS uses at ETTP, but to date no link has been identified to the K-31 and K-33 cascade operations or the associated cooling towers and switchyards located in this area.

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Table 3.1. Summary statistics for 21 K-31/K-33 wells, unfiltered groundwater 2016-2020 Non-detect Constituent Freq. of t:

Detection Units Detection Limits Min I Max a

Minb Meanb Median b

Maxb S.D.b  :- - - tt Min 21 K-31/K-33 wells unfiltered groundwater 2016-2020 Detected Mean Max S.D. Dist.

UCL 95b UTL 95/95b MCL Freq. >

MCL Metals Aluminum 37 / 89 mg/L 0.019 0.045 0.01 0.84 0.019 47.5 5.18 0.02 1.99 47.5 7.99 X* 3.26 47.5 -- --

Antimony Arsenic Barium Beryllium Cadmium 17 / 89 17 / 89 89 / 89 5 / 89 8 / 89 mg/L mg/L mg/L mg/L mg/L 0.000049 0.00046 0.000074 0.000062 I.0.001 0.005 0.001 0.0003 0.0000245 0.00023 0.003 0.000037 0.000031 0.0007202 0.002 0.048 0.0002097 0.0001131 0.000049 0.00046 0.038 0.000074 0.000062 0.026 0.017 0.123 0.003 0.003 0.028 0.00005 0.00082 0.003 0.009 0.0009865 0.00023 0.002 0.0002431 0.00011 0.003 0.006 0.048 0.002 0.000606 0.026 0.017 0.123 0.009 0.002 0.006 0.004 0.028 0.004 0.000667 X*

X*

X X*

X*

0.002 0.003 0.06 0.0007195 0.0002336 0.026 0.017 0.123 0.009 0.002 0.006 4 / 89 0.01 2 / 89 2 0 / 89 0.004 1 / 89 0.005 0 / 89 Chromium 68 / 89 mg/L 0.001 0.003 0.00055 0.172 0.022 4.49 0.646 0.004 0.225 4.49 0.736 X* 0.473 4.49 0.1 15 / 89 Chromium, hexavalent 2/2 mg/L -- -- 0.035 0.062 0.062 0.089 0.038 0.035 0.062 0.089 0.038 D 0.18 0.089 -- --

Copper 50 / 89 mg/L 0.0003 0.009 0.00015 0.005 0.000787 0.11 0.014 0.000344 0.008 0.11 0.019 X* 0.011 0.11 1.3 0 / 89 Lead 19 / 89 mg/L 0.00039 0.003 2.0E-04 0.001 3.9E-04 0.032 0.004 0.00042 0.004 0.032 0.008 X* 0.003 0.032 0.015 1 / 89 Mercury 7 / 40 mg/L 0.000067 0.000067 0.0000335 0.0000879 0.000067 0.00061 0.0000886 0.000072 0.000186 0.00061 0.000197 X* 0.0001539 0.00061 0.002 0 / 40 Nickel 62 / 89 mg/L 6.0E-04 0.003 0.0003 0.099 0.002 1.84 0.276 0.0006 0.142 1.84 0.324 X* 0.227 1.84 0.1 17 / 89 Selenium 54 / 89 mg/L 0.00065 0.006 0.00028 0.006 0.002 0.03 0.008 0.00028 0.009 0.03 0.009 X* 0.01 0.03 0.05 0 / 89 Thallium 6 / 89 mg/L 0.0000041 0.0006 0.00000205 0.0000154 0.0000041 0.00065 0.0000686 0.00001 0.000133 0.00065 0.000253 X* 0.0000513 0.00065 0.002 0 / 89 Uranium 81 / 89 mg/L 0.0000049 0.000067 0.00000245 0.0006268 0.000485 0.00359 0.000578 0.00003 0.000688 0.00359 0.000575 X* 0.0008955 0.004 0.03 0 / 89 Radionuclides Alpha activity 34 / 88 pCi/L 1.88 4.97 -1.37 3.05 1.46 48.4 6.17 1.35 6.48 48.4 8.92 X 5.92 48.4 15 4 / 88 3-4 a One-half of the detection limits shown are used as proxy values for non-detected organics and inorganics when the Kaplan-Meier statistic cannot be calculated.

b This summary statistic is calculated using both detects and non-detects.

Dist. = distribution Distribution flags are defined as:

D = The distribution was not determined with fewer than six samples, so nonparametric is assumed. UCL95 was not calculated with fewer than two samples.

L = lognormal. UCL95 was calculated using Lands statistic, Chebyshev minimum variance unbiased estimator, or nonparametric Chebyshev inequality method.

X = neither normal, lognormal nor gamma. UCL95 was calculated using a nonparametric bootstrap or the nonparametric Chebyshev inequality method.

MCL = Environmental Protection Agency maximum contaminant level from May 2020.

mg/L = milligrams per liter pCi/L = picocuries per liter S.D. = standard deviation UCL95 = upper confidence limit on the mean concentration with 95% confidence.

UTL95/95 = upper tolerance limit on individual concentrations with 95% confidence and 95% coverage. A nonparametric UTL95/95 requires at least 59 samples.

-- = Not applicable, not available or insufficient data to calculate the statistic.

• The mean, median, standard deviation, UCL95 and UTL95/95 were calculated using Kaplan-Meier since there are non-detects present with at least two distinct detected results.

Table 3.2. MCL exceedances in February-March 2020 groundwater samples in the K-31/K-33 Area Unfiltered Filtered Turbidity Arsenic UNW-039 0.0135 J 0.005 U 207 MCL = 0.01mg/L UNW-045 0.0171 J 0.005 U 1,000 Beryllium UNW-045 0.00934 0.0002 U 1,000 MCL = 0.004 mg/L Chromium BRW-031 0.169 0.168 1 MCL = 0.1 mg/L UNW-039 0.473 0.00784 J 207 UNW-045 0.105 0.00507 J 1,000 Lead UNW-045 0.0321 0.0005 U 1,000 MCL = 0.015 mg/L Nickel UNW-043 0.203 0.199 2 MCL = 0.1 mg/L UNW-039 0.517 0.065 207 UNW-083 0.108 0.105 2 Note: Green shading indicates MCL exceedance.

BRW = bedrock well MCL = maximum contaminant level mg/L = milligram per liter UNW = unconsolidated zone well 3.1.3 Fate and Transport Pathways Primary Fate and Transport pathways are summarized below:

• Historical releases occurred to the unconsolidated soils and leached downward to the water table via rainwater infiltration. The unconsolidated materials are generally comprised of a very high percentage of clay with minor silty clay and sandy clay. The high clay content of the unconsolidated material results in a low permeability, high residual moisture content, and a generally high retardation coefficient for most of the potential K-31/K-33 Area contaminants. Most of the potential contaminants are considered relatively immobile in the unconsolidated soil materials based on partition coefficient (Kd) factors from published sources (Shepard and Thibault 1990; EPA 1996) and derived for these chemicals for previous studies conducted on the ORR and at ETTP (Phase 2 Remedial Investigation/Baseline Risk Assessment Report and Feasibility Study for the K-1070-C/D Classified Burial Ground at the Oak Ridge K-25 Site, Oak Ridge, Tennessee [DOE/OR/01-1297&D2]; Report on the Remedial Investigation of Bear Creek Valley at the Oak Ridge Y-12 Plant, Oak Ridge, Tennessee

[DOE/OR/01-1455/V2&D1]; and Remedial Investigation Report for East Tennessee Technology Park, Oak Ridge, Tennessee [DOE/OR/01-1778&D1]).

• The unconsolidated zone is underlain by bedrock of the upper Knox Group and the lower Chickamauga Group formations. Rocks of the Chickamauga Group underlie the southeastern two thirds of the K-31/K-33 Area and rocks of the Knox Group occupy the northwestern third of the property.

Structurally, these formations dip to the southeast. The angle of dip ranges from 20 to 50 degrees to the southeast based on measurements obtained from bedrock exposures along Poplar Creek (Lemiszki 1995). For the most part contamination is in the unconsolidated zone wells; however, there are very low concentrations of chromium detected in BRW-031. Figures 3.1 and 3.2 show potentiometric surface maps for the unconsolidated zone and bedrock, respectively. The pre-construction topographic map indicates the occurrence of sinkholes in the K-31/K-33 Area prior to site grading for construction of the K-31/K-33 facilities (Fig. 3.3). All of these sinkholes were filled during construction of the K-31/K-33 buildings.

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• Figure 3.4 shows the topographic surface, based on light detection and ranging (LiDAR) data, for the K-31/K-33 Area. The lack of topographic relief over most of the K-31/K-33 Area is evident in this figure. Runoff occurs as overland sheet flow directly to Poplar Creek during storm events, as there are no established surface streams draining the area. Discharges of storm water are also managed by an extensive storm drain piping system, as well as through lined channels, ditches, swales, and similar structures. In the past this storm drain system managed rainfall from large building roof drains. Now, this system is dry except under significant rainfall conditions. Figure 3.5 provides a map of the K-31/K-33 Area storm drain network and storm water outfalls. SD-590, SD-650, SD-660, SD-670, and SD-694 on the east side of the site were grouted closed in the summer of 2020. Surface runoff and storm drains also discharge to the K-901-A Holding Pond in the westernmost portion of the K-31/K-33 Area. National Pollutant Discharge Elimination System (NPDES) sampling conducted in 2018 - 2019, prior to grouting of the selected storm drains, indicated the primary issues in the storm water system are low-level hits of mercury and PCBs, which has been the historical issue in this system for decades (Table 3.3). There were detections of lead at levels an order of magnitude below the MCL.

There was a detect of chromium at SD-590 of 23 µg/L, significantly below the MCL. All of these storms drains have since been plugged and abandoned. Further evaluation of the storm drain system in the K-31/K-33 Area, and potential actions, is being conducted under the ETTP NPDES Program.

Table 3.3. Surface water analytical results exceeding water quality criteria from the K-31/K-33 Area storm drain sampling effort, 2018-2019 Hexavalent Lead Mercury chromium PCB-1254 TDEC Fish and TDEC Recreation, TDEC Fish and TDEC Recreation, Aquatic Life, organisms only Aquatic Life, organisms only continuous criterion criterion continuous criterion criterion Outfall (2.5 µg/L) (51 ng/L) (11 µg/L) (0.000064 µg/L) 510 5.68 530 3.88 590 23 660 3.68 146 0.0456 690 0.0464

µg/L = micrograms per liter ng/L = nanograms per liter PCB = polychlorinated biphenyl TDEC = Tennessee Department of Environment and Conservation Routine surface water sampling of Poplar Creek, the Clinch River, and the K-901 Pond are reported in the DOE Annual Site Environmental Report [Oak Ridge Reservation Annual Site Environmental Report 2019 (DOE/CSC-2513)] and the ORR Remediation Effectiveness Report [2020 Remediation Effectiveness Report for the U. S Department of Energy Oak Ridge Site, Oak Ridge, Tennessee (DOE/OR/01-2844&D1)].

Monitoring results indicate that there are no impacts to surface water in these bodies from the K-31/K-33 storm drain outfall discharge. The Clinch River and Poplar Creek are addressed in the Record of Decision for the Clinch River/Poplar Creek Operable Unit (DOE/OR/01-02-1547&D3).

3-6

LEGEND: GEOLOGY LEGEND:

c::::::::J.................................... .BUILDING Ocy......... CATHEYS FORMATION

= * ............... .... .. ...... .. ASPHALT

=====* .. ....... ..... ........ .. .. ... ..GRAVEL

+-+-+-* ............... . . . ........ RAILROAD TRACKS ROAD ROAD Oh ........ HERMITAGE LIMESTONE Oca......... CARTERS LIMESTONE Olb.......... LEBANON LIMESTONE UCOR an Amentum-led partnership with Jacobs

- x -.. . .. ........... ....... ........ **FENCE LINE Ord ........ ... RIDLEY LIMESTONE

- - - ****.******.**..*..***.*** K-31/K-33 AREA Om... MURFREESBORO LIMESTONE,___ _ _ _ _ _ _ _ _ _ _ _ __

• . .. . .................. . .. .... .... ABANDONED WELL Ops POND SPRING FORMATION EAST TENNESSEE

© . . .............UNCONSOLIDATED MONITORING WELL Oma.. . MASCOT DOLOMITE Ci) **..* * ******** UNCONSOLIDATED PIEZOMETER WELL Ok .. ::::: :KiNGSPORT FORMATION TECHNOLOGY PARK rnre1::: *wAi'ER *.LEVEL* Et.Eiikrioi-i *o/~6;~6u~~ Olv.......... LONGVIEW DOLOMITE OAK RIDGE RESERVATION

~.. LINE OF EQUAL WATER LEVEL ELEVA1iON ,.- - ......... GEOLOGIC CONTACT OAK RIDGE , TENNESSEE CJJ* *.. *.. *, ... PRE-CONSTRUCTION SINK HOLE _.. - .,_ ... * .. *** .THRUST FAULT DRAWN BY: RE.V. NO./DAlE: 00 FlLE:

P. HOLt.t - 12/3/20 C:\15031\DWGS\T45_K33_UCON-SINK Fig. 3.1. Unconsolidated zone potentiometric surface in the K-31/K-33 Area, October 2017.

3-7

LEGEND: GEOLOGY LEGEND:

c:::::::J............ ... ..... .. .. . ....... . ... .BUILDING Ocy... ... ... CATHEYS FORMATION

= * .. .. .. ...... .. .. .. .... ....... ASPHALT

== = = =* .. ... ..............*.......... GRAVEL

+-+-+-* .. .. .. . .. .... . .. .. . . ... ... RAILROAD TRACKS ROAD ROAD Oh ........ HERMITAGE LIMESTONE Oca.... ..... CARTERS LIMESTONE Olb.... ... ... LEBANON LIMESTONE UCOR an Amentum-~d partnershipwith Jacobs

- x -................. * * * * * * * * * * * * * * ** FENCE LINE Ord ......... .. RIDLEY LIMESTONE

- - - ................. * * * * * * * *

• K-31/K-33 AREA Om.. .MURFREESBORO LIMESTONE

• • .. .. .. .. ...... * * * * ** ********** .. ABANDONED WELL Ops POND SPRING FORMATION EAST TENNESSEE e .... ............ ... .... BEDROCK MONITORING WELL Oma ... MASCOT DOLOMITE G...... ... ... .. UNCONSOLIDATED PIEZOMETER WELL Ok * * * * * * * * *

• TECHNOLOGY PARK c:::::::::J . .. . .. .. .... ... . .. .. ....... . .. . .. .voe PLUME 01 .... ... .KINGSPORT FORMATION 745.51 ... WATER LEVEL ELEVATION ON 10/10/17 V...... .... LONGVIEW DOLOMITE OAK RIDGE RESERVATION

~** LINE OF EQUAL WATER LEVEL ELEVAtlON .,,... - -. . . .* GEOLOGIC CONTACT OAK RIDGE, TENNESSEE

~ * *********--PRE-CONSTRUCTION SINK HOLE ~ - , . . . .........THRUST FAULT DRAWN BY: REV. NO./DATE: CAD Fllf:

P. HOLt.4 - 12/3/20 C:\15031\DWGS\T45_K33_ 8R_SINK Fig. 3.2. Bedrock potentiometric surface in the K-31/K-33 Area, October 2017.

3-8

r

r ...

... 0::

0:: 0 0 z

...z ;:"'

(J

... ~z 0::

J: 0 450 FT Fig. 3.3. Pre-construction topographic map from 1941 (USGS Elverton quadrangle map, 1941).

3-9

3-10 Fig. 3.4. Topographic surface from LiDAR.

FORMER K-33 BUILDING FORMER K-31 BUILDING

'\

\

\

\.

\-

C;:1-=- _\. _,.. __________ II II

\ II

\ \\

\

II

\\I ~_/ (.

\ II II LEGEND:

• • • .****.****.******.****.******.****. **

• ASPHALT ROAD 5.39°+/-

===== ...........................................GRAVEL ROAD

- x - .. . .. ........ .. ..... .. ... ...... . .. ... ... ... . .... . .. .FENCE

-+-<--+-<e-+- *** * ********************************** RAILROAD TRACKS 0 :c:

UCOR anAmeorum*led partnership with Jacooo

,------- .. . ..... *..... . .... . ...... . .... . ...... . .... . ..... STREAM f-0::: a::

• ~ , .. . .... . *..... . .... . ...... . .... . ... .. . . . POND OR RIVER C) 0

z

_ _ _ ......................................... STORM DRAIN w ::,

EAST TENNESSEE w

0 530 .... .... . . ... . ......... ... ... .. . ...... . .... . .......... OUTFALL t:: a:: TECHNOLOGY PARK 10 694 I............................... OUTFALL GROUTED IN 2020 (/) f- OAK RIDGE RESERVATION 0

--- 300 SCALE: 1" = 600' 600 DRAWN BY:

P. HOLM O OAK RIDGE, TENNESSEE REV. NO./DATE:

12/3/20 CAD Fll£: C:\15031\DWGS S7S*K33*SD-GROUTED Fig. 3.5. Storm drain network in the K-31/K-33 Area.

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3.2 DATA QUALITY OBJECTIVES FOR THE SUPPLEMENTAL SAMPLING The Data Quality Objectives (DQOs) for this supplemental sampling event focus on the remaining questions that need to be answered to produce the RI/FS. The remaining questions have been identified through various project team meetings and follow on correspondence with EPA and TDEC. Table 3.4 summarizes this focused DQO effort.

Table 3.4. DQOs for the K-31/K-33 Area groundwater evaluation DQO Step Site-specific

1. State the Problem

• Groundwater at some wells in the K-31/K-33 Area has been impacted by contaminants of concern, primarily metals, at concentrations that slightly exceed MCLs.

2. Identify the

• Are concentrations of COCs present in groundwater exhibiting decreasing concentration Decisions trends that will support an MNA decision or will active remediation be required?

3. Specify inputs to General inputs to the decision are driven by requirements for making a Monitored Natural the decision Attenuation decision per Monitored Natural Attenuation of Inorganic Contaminants in Groundwater (EPA/600/R-07/139). These inputs include:

• Are there active sources of contamination to groundwater?

• Are concentrations of metals in wells increasing, decreasing, or stable?

• Is contamination migrating or stable? Is the flowpath known?

• What other information supports attenuation mechanisms at the site?

• Are there special or emerging contaminant issues (per- and polyfluoroalkyl substances

[PFAS]) that should be addressed at this time?

• Are PFAS below the 40 parts per trillion (ppt) screening level (https://www.epa.gov/pfas/interim-recommendations-addressing-groundwater-contaminat ed-pfoa-and-pfos)?

4. Study boundary Spatial boundaries: The K-31/K-33 Area, between Poplar Creek on the east and south and the K-1065 Area on the west and the base of Blackoak Ridge on the north. Vertical extent includes the unconsolidated zone, from the ground surface down to the top of bedrock, and the top of bedrock down to an elevation of approximately 690 ft amsl (bottom elevation of deepest bedrock well with MCL exceedance in last five years).

Temporal boundaries: The temporal boundary of the study is limited to the upcoming period of time prior to producing a final RI/FS, approximately one year starting with Fall 2020. (Additional monitoring may continue to support the selected remedial action.)

5. Decision rules

• Concentrations of COCs will be compared to TDEC and EPA MCLs to determine the extent of impacts in groundwater.

• Concentration trends will be evaluated to determine if trends are stable, decreasing, increasing, or indeterminate.

• Geochemical indicators will be used to support an MNA alternative.

6. Specify limits on All field and laboratory work will be conducted in accordance with the Quality Assurance decision error Project Plan for the East Tennessee Technology Park Site-Wide Residual Contamination Remedial Investigation Work Plan, Oak Ridge, Tennessee (RIWP QAPP), which is Appendix A of the ETTP Site-Wide RIWP (DOE/OR/01-2154&D2).

7. Optimize sample See Table 3.5 design amsl = above mean sea level MCL = maximum contaminant level COC = contaminant of concern MNA = monitored natural attenuation DQO = data quality objective QAPP = Quality Assurance Project Plan EPA = U.S. Environmental Protection Agency RI = Remedial Investigation ETTP = East Tennessee Technology Park RIWP = Remedial Investigation Work Plan ft = feet 3-12

Table 3.5. Sampling needs evaluation Additional Data Decision Inputs Data Needs Available Data Recommended data needs Are there active Verify No Further 366 Zone 2 soil Verify no soil Grab (unfiltered and sources of Action decisions and concrete sources to filtered) groundwater contamination to on soil sources in samples from 10 groundwater in samples from new groundwater in K-31/K-33 exposure units building footprint temporary piezometers areas not previously exposure units from 0 - 15 bgs sampled Are concentrations Contaminant Historical data 3 - 4 additional Quarterly monitoring of metals in wells concentration collected in the data points for from Fall 2020 through increasing, trends that support 1990s through wells that do not summer 2021 (four decreasing, or a statistically 2020, with an have sufficient data rounds) at existing wells stable? significant trend emphasis on the in the past five for metals including Cr+6, past five years years gross alpha/beta, VOCs, and limited isotopic uranium Is contamination Confirm Water level and Water level data Synoptic water level migrating or stable? horizontal and concentration near former filled measurements from Is the flow path vertical flowpaths data from sinkholes existing wells and five known? IN building existing well new temporary footprint areas: network located piezometers in center of Validate absence downgradient of site of continuing known source Confirm absence Grab (filtered and sources in areas of continuing unfiltered) groundwater K-31/K-33 sources upgradient samples from new footprint of existing wells temporary piezometers What other Understanding of Geochemical Solids grain size Grain Size analysis information supports geochemical data (pH, DO, attenuation conditions in the ORP, mechanisms at the soil and Anion/Cation),

site? groundwater turbidity data, filtered vs.

unfiltered data analysis; Kd analyses Are there special or Cr+6 and PFAS Cr+6 will be collected emerging analytical results quarterly as indicated contaminant issues above. The second and that should be third quarter of addressed at this monitoring existing wells time will include PFAS analysis; If PFAS are detected > action levels an I

• additional round (Q4) will be performed bgs = below ground surface Cr+6 = hexavalent chromium DO = dissolved oxygen Kd = partition coefficient ORP = oxidation-reduction potential PFAS = per and polyfluoroalkyl substances Q4 = fourth quarter 3-13

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3-14

4. SAMPLING AND ANALYSIS APPROACH 4.1 PROPOSED SAMPLING AND ANALYSIS 4.1.1 Quarterly Sampling Table 4.1 provides an analysis of wells at K-31/K-33 Area. Data for the past five years was reviewed to determine wells for which additional data were needed to establish concentration trends, assuming that 7 - 8 data points are required to establish a trend. (Please note, some of the wells have data from the late 1990s, however it is assumed these data are too old to use for trend analysis.) Wells with MCL exceedances in the past five years include three well pair locations (UNW-039/BRW-027, UNW-043/BRW-030, and UNW-080/BRW-066) located in the southern portion of the K-31/K-33 Area; five individual unconsolidated zone monitoring wells (UNW-040, UNW-045, UNW-081, UNW-082, and UNW-083); and one individual bedrock well (BRW-031). The wells sampled by the Water Resources Restoration Program (WRRP) have sufficient data for trend analysis; however, the additional wells do not. This subset of wells have been identified for quarterly monitoring for an additional year. The WRRP wells will also continue to be monitored semiannually during this time.

A summary of the K-31/K-33 monitoring wells equipped with micropurge, low-flow sampling pumps is shown in Table 4.2, and it can be seen that of the proposed wells for quarterly sampling, only UNW-039 is not equipped with a dedicated micropurge pump. Table 4.2 also provides a summary of the well construction information for the K-31/K-33 monitoring wells.

Quarterly groundwater samples will be analyzed for metals (unfiltered and filtered), gross alpha and beta, and selected geochemical parameters to aid in the evaluation of MNA. Both unfiltered and field-filtered samples will be collected for metals analyses. The gross alpha/beta results will be used to determine if isotopic analyses will be performed. If the alpha result is greater than 15 pCi/L then isotopic uranium analyses will be performed, and if the beta result is greater than 50 pCi/L then analysis for technetium-99 will be performed. An exception to this will be the analysis for isotopic uranium at wells UNW-040 and UNW-081, which have had gross alpha activity MCL exceedances in the past five years. Table 4.3 provides a detailed analyte list and the analytical methods for K-31/K-33 groundwater samples.

To ensure that PFAS/PFOS compounds have not impacted groundwater in the K-31/K-33 Area, selected monitoring well samples will be analyzed for PFAS/PFOS in the second quarter sampling event. The PFAS/PFOS chemicals to be reported include the 18 parameters as described in EPA Method 537.1 and provided on Table 4.4. The wells to be sampled will include: the 13 wells to be sampled quarterly and three additional wells to complete sample collection from the unconsolidated zone and bedrock monitoring wells at six well pairs; and two individual unconsolidated zone wells; and one individual bedrock well. These locations are indicated on Fig. 4.1. The latest EPA interim recommendations for screening guidance that were issued December 19, 2019, will be followed. In summary, this includes the following:

• Screening sites using a recommended groundwater screening level based on a target Hazard Quotient of 0.1 for perfluorooctanoic acid (PFOA) or PFOS individually, which is currently 40 ng/L or parts per trillion ppt

• Using the PFOA and PFOS Lifetime Drinking Water Health Advisories of 70 ppt (combined or individually) as the recommended Preliminary Remediation Goal (PRG) for groundwater that is a current or potential source of drinking water, where no state or tribal MCL or other applicable or relevant and appropriate requirements (ARARs) are available or sufficiently protective 4-1

• In situations where groundwater is currently being used for drinking water, EPA expects that responsible parties will address levels of PFOA and/or PFOS over 70 ppt.

This guidance is based on EPAs current scientific understanding of the toxicity of PFOA and PFOS and is consistent with other relevant EPA guidance. EPA considers the recommendations to be interim and may revise this guidances recommendations as new information becomes available. For example, if the Agency promulgates a federal ARAR, such as a national drinking water standard, for PFOA or PFOS this guidance would be revised, replaced, or rescinded.

If there are detections of PFAS/PFOS in groundwater in the K-31/K-33 Area in the second or third quarter sampling results that are greater than the EPA action level of 40 ng/L, additional PFAS/PFOS sampling will be conducted during the fourth quarter sampling event. The WRRP Programmatic QA and sampling procedure documents are being revised to include PFAS sampling, and training to sampling protocols has been completed.

All sample data listed in Table 4.1 will be collected and the results will be provided in the K-31/K-33 RI/FS.

This data includes the groundwater samples collected from the existing perimeter wells as well the samples collected from the temporary piezometers. Both unfiltered and filtered sample data will be reported; however, only unfiltered sample results from the wells will be evaluated in determining groundwater conditions and human health risk.

As described in Addendum 1 to the Site-Wide RIWP, all groundwater samples will be collected under the approved Quality Assurance Project Plan for the Water Resources Restoration Program, U.S. Department of Energy, Oak Ridge Reservation, Oak Ridge, Tennessee (UCOR-4049; WRRP QAPP), which identifies the procedures that will be followed in the collection, custody, and handling of the samples. The WRRP QAPP also integrates with the Data Management Implementation Plan for the Water Resources Restoration Program, Oak Ridge, Tennessee (UCOR-4160). All WRRP-implementing documents are prepared in accordance with applicable professional technical standards; EPA requirements; government regulations; DOE Orders; and UCOR LLC procedures, guidelines, and requirements in response to CERCLA actions on the ORR.

Well purging will be performed prior to sampling per WRRP procedures. Sampling of the monitoring wells will begin immediately after completion of purging. Purging will be accomplished through use of the pump installed in the well for sample collection. Purging will continue until the water quality parameters, which may include pH, specific conductance, dissolved oxygen (DO), oxidation reduction potential (ORP),

turbidity, and/or temperature, have stabilized. The groundwater sample volume obtained after parameter stabilization will be used for laboratory chemical analysis. Additional information on the quality assurance requirements applicable to the analytical laboratory are provided in the WRRP QAPP.

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Table 4.1. K-31/K-33 Area groundwater sampling results summary and wells proposed for further sampling Past 5 years Past 5 years Statistically Retain for Well Detections > MCL Average > MCL significant Recent MCL further Notes number trend exceedances Filtered Unfiltered Filtered Unfiltered sampling established Only two recent samples; MCL exceedances BRW-027 N Y N Y N Y Sb and Cr in highly turbid sample BRW-028 N N N N NA N No results > MCL BRW-030 Y Y N N Y Y Continue WRRP semi-annual sampling Cr Three recent samples bounce around the BRW-031 Y Y Y Y N Y Cr MCL BRW-032 N N N N NA N No results > MCL BRW-062 N N N N NA N No results > MCL BRW-063 N N N N NA N No results > MCL BRW-064 N N N N NA Na No results > MCL BRW-065 N N N N NA N No results > MCL BRW-066 N N N N Y Ya Continue WRRP semi-annual sampling None 4-3 BRW-067 N N N N NA Na No results > MCL MCL exceedances in turbid sample collected UNW-039 N Y N Y N Y As, Cr, and Ni with bailer UNW-040 N Y N Y N Y Two alpha exceedances Alpha UNW-043 Y Y Y Y Y Y Continue WRRP semi-annual sampling Cr, Ni, and As As, Be, Cr, and UNW-045 N Y N Y N Y High turbidity Pb UNW-078 N N N N NA Y No results > MCL Sb, Cr, and UNW-080 N Y N Y Y Y Continue WRRP semi-annual sampling Alpha UNW-081 N Y N Y N Y Single alpha exceedance Alpha One antimony > MCL in turbid sample; UNW-082 Y Y Y N N Y Sb average below MCL UNW-083 Y Y Y Y N Y Possible downward trend Sb, Cr, and Ni Quarterly monitoring > MCL 9 Non-WRRP Wells Total WRRP wells 4 WRRP wells

Table 4.1. K 31/K 33 Area groundwater sampling results summary and wells proposed for further sampling (cont.)

Past 5 years Past 5 years Statistically Retain for Well Detections > MCL Average > MCL significant Recent MCL further Notes number trend exceedances Filtered Unfiltered Filtered Unfiltered sampling established Additional wells to support CSM:

Additional Isotopic Analysis UNW-040 Alpha Isotopic UNW-081 Alpha Isotopic Additional PFAS Analysis 13 wells, Q2 and Q3; Q if trigger of 40 ng/L PFAS/PFOS Analysis exceeded.

a Additional VOC Analysis BRW-064 Historical VOC detects above the MCL BRW-066 Historical VOC detects above the MCL BRW-067 Historical VOC detects above the MCL Additional Temporary Piezometers to be Installed 4-4 Temporary piezometers to be installed will 5 new temporary piezometers be sampled and analyzed for metals, VOCs, Alpha isotopic, and PFAS/PFOS Red font indicates wells retained for sampling that are not in the WRRP.

Blue font indicates wells retained for sampling that are in the WRRP.

As = arsenic Be = beryllium BRW = bedrock well Cr = chromium CSM = conceptual site model MCL = maximum contaminant level Ni = nickel N = no NA = not applicable Pb = lead PFAS = per- and polyfluoroalkyl substances PFOS = perfluorooctane sulfonic acid Q2 = second quarter Q3 = third quarter Sb = antimony UNW = unconsolidated zone well WRRP = Water Resources Restoration Program Y = yes

SCALE: 1" = 600' LEGEND:

- - - ............... . .. K-31/K-33 AREA c=:::J .... ........... ... BUILDING

.. ..... ..... ........ ... . ABANDONED WELL [+ ;~;;>;)..... ... CONCRETE SLAB 8 ...... ... . BEDROCK MONITORING WELL r - - - DEMOLISHED BUILDING 7

• UCOR an Amenlum*led partnershipwilh Jacobs ffiUNCONSOLIDATED MONITORING WELL

'.:..=_-;~ .......... .. ... FENCE LINE

(:)UNCONSOLIDATED PIEZOMETER WELL I I....................... voe PLUME EAST TENNESSEE PROPOSED WELLS FOR TECHNOLOGY PARK

'-----'I ......... ADDITIONAL SAMPLING OAK RIDGE, TENNESSEE DRAWN BY: REV. DATE: CAO FTLEC:\ 15031 \ DWGS P. HOLM 12/3/20 90-K33-PROP-WELLS Fig. 4.1. Proposed monitoring wells for additional sample collection in the K-31/K-33 Area.

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Table 4.2. Summary of well conditions and wells with dedicated pumps for micro-purge, low-flow sample collection Tag Screen Middle DTW Diameter HWC Volume Well ID depth interval of Comments (ft)b (in.) (ft) (gal)

(ft)a (ft) screen BRW-027 71.75 21.16 4 20 10 50.59 33.0 Micropurge installed BRW-028 46.34 15.23 4 10 5 31.11 20.3 Micropurge installed BRW-030 54.49 21.45 4 20 10 33.04 21.6 Micropurge installed BRW-031 50.36 30.95 4 10 5 19.41 12.7 Micropurge installed BRW-032 121.9 41.5 4 20 10 80.4 52.5 Micropurge installed BRW-062 26.02 16.75 4 10 5 9.27 6.1 Micropurge installed BRW-063 85.71 27.87 4 10 5 57.84 37.8 Micropurge installed BRW-064 71.46 22.1 4 10 5 49.36 32.2 Micropurge installed BRW-065 67.86 22.1 4 10 5 45.76 29.9 Micropurge installed BRW-066 55.08 20.22 4 5 2.5 34.86 22.8 Micropurge installed BRW-067 64.17 21.65 4 10 5 42.52 27.8 Micropurge installed UNW-039 14.09 10.39 4 5.5 2.75 3.7 2.4 Insufficient water column UNW-040 19.55 15.24 4 5.5 2.75 4.31 2.8 Micropurge installed UNW-043 28.98 21.64 4 10.5 5.25 7.34 4.8 Micropurge installed UNW-044 24.81 24.48 4 10.5 5.25 0.33 0.2 Insufficient water column UNW-045 52.42 43.04 4 10 5 9.38 6.1 Micropurge installed UNW-078 38.03 26.37 4 10 5 11.66 7.6 Micropurge installed UNW-080 31.02 20.75 4 10 5 10.27 6.7 Micropurge installed UNW-081 38.06 20.59 4 10 5 17.47 11.4 Micropurge installed UNW-082 40.00 22.32 4 10 5 17.68 11.5 Micropurge installed UNW-083 41.13 29.76 4 10 5 11.37 7.4 Micropurge installed a

Depth based on tagged depth of well in summer 2019 b

Depth to water based on measurement in June 2019 BRW = bedrock well DTW = depth to water ft = feet gal = gallon HWC = height of water column ID = identification in. = inch UNW = unconsolidated zone well Table 4.3. Proposed analyte list for the K-31/K-33 Area Analyte Laboratory method Gross Alpha/Beta GFPC Volatile Organic Compounds (VOCs) a SW846-8260 Metals and Trace Elementsb SW-846-6010/6020 Chromium, hexavalent (Cr+6) ASTM-D5257 Perfluorooctanoic acid/Perfluorooctane sulfonic acid EPA-537.1 Tc-99 Beta LSC Uranium isotopes Alpha Spectrometry a

VOCs will be analyzed at select wells that have had historical VOC detects above the MCL and at the 5 temporary piezometers b

Metals and trace elements analysis includes cations ASTM = American Society for Testing and Materials Cr+6 = hexavalent chromium EPA = U.S. Environmental Protection Agency GFPC = Gas Flow Proportional Counting.

LSC = liquid scintillation counting Tc-99 = technetium-99 4-6

Table 4.4. Proposed PFOS/PFAS Parameters to be reported Parameter Perfluorooctane sulfonic acid (PFOS)

Perfluoroundecanoic acid (PFUnDA)

N-Methylperfluorooctane sulfonamido acetic acid (NMeFOSAA)

N-Ethylperfluorooctane sulfonamido acetic acid (NEtFOSAA)

Perfluorohexanoic acid (PFHxA)

Perfluorododecanoic acid (PFDOA)

Perfluorooctanoic acid (PFOA)

Perfluorodecanoic acid (PFDA)

Perfluorohexane sulfonic acid (PFHxS)

Perfluorobutane sulfonic acid (PFBS)

Perfluoroheptanoic acid (PFHpA)

Perfluorononanoic acid (PFNA)

Perfluorotetradecanoic acid (PFTDA)

Perfluorotridecanoic acid (PFTrDA) 11-Chloroeicosafluoro-3-oxaundecane-1-sulfonic acid 4,8-Dioxa-3H-perfluorononanoic acid 9-Chlorohexadecafluoro-3-oxanone-1-sulfonic acid Hexafluoropropylene oxide dimer acid 4.2 TEMPORARY PIEZOMETER INSTALLATION AND MONITORING Figure 4.2 shows the proposed locations of five new temporary piezometers. The primary purpose of the temporary piezometers is to confirm the potentiometric surface in the area of the former K-31/K-33 building footprint and to ensure groundwater contamination is not flowing towards the middle of the site. In the case that the push probe hits refusal before reaching groundwater a field decision will be made to step out based on best knowledge of the former sinkholes as defined in Fig. 4.2.

The temporary piezometers will be 1-inch diameter, and finished with sand filter pack and bentonite. They will be approximately 35-ft in depth. Based on a rough average of groundwater levels at the site the depth to water is in the range of 10 to 19.5 ft bgs. It is assumed the wet season water table is likely to be in the range of about 1.5 foot higher. Since the current effort is specifically targeting the old preconstruction sinkhole areas there could be variability not accounted for in the historical data.

They will be used for the following types of sample collection/measurements:

• Two soil samples from each direct push technology (DPT) temporary piezometer for grain size analyses (samples collected during drilling operations). The samples will be collected in the middle portion of the unconsolidated zone, and in the weathered bedrock zone. However, if the lithology is similar across the entire zone, one sample will be collected.

• Synoptic water level measurements will be collected after the temporary piezometers have been completed

• Grab groundwater samples will be collected after the temporary piezometers have been completed. The intent is to install 10 ft screens in the direct pushes that penetrate 10 ft into the groundwater table to help with the turbidity issues. Depending on the depth to water, the 1-inch wells will be sampled with either a peristaltic pump or a 1/2-inch bailer. Because of the potential for very low yield, laboratory analysis will be prioritized as follows: metals, gross alpha/beta, uranium, VOCs, and remaining analytes on Table 4.3. Both unfiltered and filtered results will be reported, but the unfiltered results may be problematic due to the likelihood of encountering highly turbid water based on sampling experience.

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Up to 10 soil samples will be collected and analyzed for grain size analyses (sieve + hydrometer). Logging of the core for lithologic description will also be completed. During DPT advancement if shallow refusal is observed then an offset is likely to be attempted. However, if refusal is encountered at significant depths (approximately >20 ft depth bgs) then a piezometer will be set with the likelihood that it will be dry. Given that this time of year is the wet season, there is the possibility that the GW table could rise and enter the screen over the next month or two.

Due to near term reindustrialization plans for the site, the DOE intends to collect the water level and water quality data and abandon the temporary holes by removing the wells and backfilling the holes.

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2440658.82 588908.44 Proposed Locations of 2441196.34 588383.56 5 New EPA Requested N 2440462.78

+

OPT Temporary Piezometers 587865.02 0 250 500 2439977.46 587199.43 MFeet 2440917.9 587186.91

\ \&\

Fig. 4.2. Proposed temporary DPT piezometer locations.

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4.3 QUALITY CONTROL DUPLICATE SAMPLES During the sampling of groundwater from the K-31/K-33 monitoring wells, quality control (QC) duplicates will be collected along with the regular groundwater samples. The exact number of duplicate samples will depend on the total number of groundwater samples collected for the project. However, the total number will be at least 10% of the entire sample population. The QC duplicates will be analyzed for the same analytes as in the original sample.

4.4 QUALITY CONTROL TRIP BLANK SAMPLES Quality control trip blanks consisting of sealed containers of American Society for Testing and Materials (ASTM) Type II or equivalent PFAS-free water will be used for the project. One trip blank will be placed into each cooler used to store portions of groundwater samples designated for volatile organic compound (VOC) analysis. These blanks will remain with the sample containers until groundwater sampling is completed and the samples are shipped to the off-site laboratory for chemical analysis.

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5. SAMPLE COLLECTION METHOD 5.1 GROUNDWATER 5.1.1 Sampling of Wells Groundwater samples to be collected from the new monitoring wells will be collected in accordance with methods and procedures consistent with those used by the current WRRP ETTP Water Quality Program.

Dedicated bladder pumps have been installed in 19 of the 21 wells (see Table 4.2) for sample collection.

Samples will be collected using micro-purge, low-flow sampling techniques, where applicable.

Collection of groundwater samples from monitoring wells will be accomplished in three general steps:

(1) measurement of field parameters, (2) well purging, and (3) groundwater sample collection. Well purge will be performed prior to sampling, per WRRP procedures. Sampling will not occur until a well has achieved stabilization parameters.

Sampling of the monitoring wells will begin immediately after completion of purging. Purging will be accomplished through use of the pump installed in the well for sample collection. Purging will continue until the water quality parameters, which may include pH, specific conductance, DO, ORP, turbidity, and/or temperature, have stabilized. The groundwater sample volume obtained after parameter stabilization will be used for laboratory chemical analysis. All groundwater samples will be transferred directly into laboratory sample containers from the sampler. Groundwater samples will be collected directly into the sample container, pre-preserved, if required, and placed on ice in a cooler for delivery to the laboratory.

5.1.2 Analytical Parameters Table 5.1 indicates the parameters to be analyzed and the laboratory methods to be used. Samples will be shipped to a fixed-base laboratory for analysis. The QAPP (UCOR-4049/R5) provides additional information on the quality assurance requirements applicable to the analytical laboratory.

PFAS analyses will include reporting the 18 PFA compounds under Method 537.1 R2.

Table 5.1 includes the project action limits (PALs), which represent the EPA Regional Screening Levels (RSLs) for all chemicals with a currently available RSL. The laboratory reporting limits (RLs) are also indicated in Table 5.1. Chemicals with PALs less than the RL will be screened against MCLs, which are greater than the RLs. All chemicals will be evaluated in accordance with the EPA risk assessment process in the Baseline Human Health Risk Assessment to be prepared for the K-31/K-33 RI/FS.

5.1.3 Quality Control Duplicate Samples During the sampling of groundwater from the monitoring wells, QC duplicates will be collected along with the regular groundwater samples. The exact number of duplicate samples will depend on the total number of groundwater samples collected for the project. However, the total number will be at least 10% of the entire sample population. The QC duplicates will be analyzed for the same analytes as in the original sample.

5.1.3.1 Quality Control Rinsate Blank Samples During the decontamination of sampling equipment used for groundwater purging and collection, QC rinsate blanks will be collected from all non-dedicated and non-disposable sample collection equipment 5-1

used to obtain groundwater samples from groundwater monitoring wells. The total number of rinsate blanks to be collected from the monitoring wells will represent approximately 5% of the entire sample population.

These samples will be collected on a regular basis throughout the implementation of investigation activities.

The QC rinsate blanks will be analyzed for the same suite of analytes as the original samples.

5.1.3.2 Quality Control Trip Blank Samples Quality control trip blanks consisting of sealed containers of ASTM Type II or equivalent water will be used for the project. One trip blank will be placed into each cooler used to store portions of groundwater samples designated for VOC analysis. These blanks will remain with the sample containers until groundwater sampling is completed and the samples are shipped to the off-site laboratory for chemical analysis.

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Table 5.1. Detailed analyte list, analytical methods, and reporting requirements for K-31/K-33 groundwater samples a Project Action Method source Method Analyte CAS No. Reporting limit Holding time Limit RAD Gross Alpha/Beta Alpha Activity 12587-46-1 15 pCi/L 5 pCi/L 180 RAD Gross Alpha/Beta Beta Activity 12587-47-2 50 pCi/L 5 pCi/L 180 RAD Tc-99 by Beta LSC Technetium-99 14133-76-7 - 10 pCi/L 180 RAD Uranium ISO by Alpha Uranium-233/234 NS632 - 1 pCi/L 180 RAD Uranium ISO by Alpha Uranium-235/236 N1047 - 1 pCi/L 180 RAD Uranium ISO by Alpha Uranium-238 24678-82-8 - 1 pCi/L 180 SW-846 6010 Arsenic 7440-38-2 0.0000052 mg/L 0.005 mg/L 180 SW-846 6010 Barium 7440-39-3 0.38 mg/L 0.001 mg/L 180 SW-846 6010 Calcium 7440-70-2 - 0.05 mg/L 180 SW-846 6010 Magnesium 7439-95-4 - 0.11 mg/L 180 SW-846 6010 Potassium 7440-09-7 - 0.05 mg/L 180 SW-846 6010 Selenium 7782-49-2 0.01 mg/L 0.006 mg/L 180 SW-846 6010 Silicon 7440-21-3 - 0.025 mg/L 180 SW-846 6010 Sodium 7440-23-5 - 0.1 mg/L 180 5-3 SW-846 6010 Vanadium 7440-62-2 0.0086 mg/L 0.001 mg/L 180 SW-846 6010 Zinc 7440-66-6 0.6 mg/L 0.0033 mg/L 180 SW-846 6020 Aluminum 7429-90-5 2 mg/L 0.0193 mg/L 180 SW-846 6020 Antimony 7440-36-0 0.00078 mg/L 0.001 mg/L 180 SW-846 6020 Beryllium 7440-41-7 0.0025 mg/L 0.0002 mg/L 180 SW-846 6020 Boron 7440-42-8 0.4 mg/L 0.052 mg/L 180 SW-846 6020 Cadmium 7440-43-9 0.00092 mg/L 0.0003 mg/L 180 SW-846 6020 Chromium 7440-47-3 0.1 mg/L 0.003 mg/L 180 ASTM D5257 Chromium, hexavalent (Cr+6) 18540-29-9 0.000035 mg/L 0.006 mg/L 1 SW-846 6020 Cobalt 7440-48-4 0.0006 mg/L 0.0003 mg/L 180 SW-846 6020 Copper 7440-50-8 0.08 mg/L 0.0003 mg/L 180 SW-846 6020 Iron 7439-89-6 1.4 mg/L 0.033 mg/L 180 SW-846 6020 Lead 7439-92-1 0.015 mg/L 0.0005 mg/L 180 SW-846 6020 Lithium 7439-93-2 0.004 mg/L 0.03 mg/L 180 SW-846 6020 Manganese 7439-96-5 43 mg/L 0.001 mg/L 180 SW-846 6020 Nickelc 7440-02-0 0.039 mg/L 0.0006 mg/L 180 SW-846 6020 Silver 7440-22-4 0.0094 mg/L 0.0003 mg/L 180

Table 5.1. Detailed analyte list, analytical methods, and reporting requirements for K 31/K 33 groundwater sample a (cont.)

Project Action Method source Method Analyte CAS No. Reporting limit Holding time Limit SW-846 6020 Strontium 7440-24-6 1.2 mg/L- 0.002 mg/L 180 SW-846 6020 Thallium 7440-28-0 0.000002 mg/L 0.0006 mg/L 180 SW-846 6020 Uranium 7440-61-1 0.0004 mg/L 0.000067 mg/L 180 SW-846 7470 Mercury 7439-97-6 0.000063 mg/L 0.000067 mg/L 14e EPAd 537.1 11-Chloroeicosafluoro-3-oxaundecane-1-sulfonic acid 763051-92-9 - 1.32 ng/L 14 e EPAd 537.1 4,8-Dioxa-3H-perfluorononanoic acid 919005-14-4 - 0.66 ng/L 14 e EPAd 537.1 9-Chlorohexadecafluoro-3-oxanone-1-sulfonic acid 756426-58-1 - 1.32 ng/L 14 e EPAd 537.1 Hexafluoropropylene oxide dimer acid 13252-13-6 - 0.66 ng/L 14 e EPAd 537.1 N-ethylperfluoro-1-octanesulfonamidoacetic acid 2991-50-6 - 1.32 ng/L 14 e EPAd 537.1 N-methylperfluoro-1-octanesulfonamidoacetic acid 2355-31-9 - 1.32 ng/L 14 e EPAd 537.1 Perfluorobutanesulfonic acid 375-73-5 600 ng/L 0.66 ng/L 14 e EPAd 537.1 Perfluorodecanoic acid 335-76-2 - 0.78 ng/L 14 e EPAd 537.1 Perfluorododecanoic acid 307-55-1 - 0.66 ng/L 14 e EPAd 537.1 Perfluoroheptanoic acid 375-85-9 - 0.66 ng/L 14 e EPAd 537.1 Perfluorohexanesulfonic acid 355-46-4 - 0.66 ng/L 14 e 5-4 EPAd 537.1 Perfluorohexanoic acid 307-24-4 - 0.8 ng/L 14 e EPAd 537.1 Perfluorononanoic acid 375-95-1 - 0.66 ng/L 14 e EPAd 537.1 Perfluorooctane sulfonic acid 1763-23-1 - 0.8 ng/L 14 e EPAd 537.1 Perfluorooctanoic acid 335-67-1 - 0.8 ng/L 14 e EPAd 537.1 Perfluorotetradecanoic acid 376-06-7 - 0.8 ng/L 14 e EPAd 537.1 Perfluorotridecanoic acid 72629-94-8 - 0.66 ng/L 14 e EPAd 537.1 Perfluoroundecanoic acid 2058-94-8 - 0.66 ng/L 14 e SW-846 8260 1,1,1-Trichloroethane 71-55-6 800 µg/L 0.333 µg/L 7 SW-846 8260 1,1,2,2-Tetrachloroethane 79-34-5 0.076 µg/L 0.333 µg/L 7 SW-846 8260 1,1,2-Trichloroethane 79-00-5 0.041 µg/L 0.333 µg/L 7 SW-846 8260 1,1-Dichloroethane 75-34-3 2.8 µg/L 0.333 µg/L 7 SW-846 8260 1,1-Dichloroethene 75-35-4 7 µg/L 0.333 µg/L 7 SW-846 8260 1,2-Dichloroethane 107-06-2 28 µg/L 0.333 µg/L 7 SW-846 8260 1,2-Dichloropropane 78-87-5 0.82 µg/L 0.333 µg/L 7 SW-846 8260 2-Butanone 78-93-3 560 µg/L 1.67 µg/L 7 SW-846 8260 2-Hexanone 591-78-6 3.8 µg/L 1.67 µg/L 7 SW-846 8260 4-Methyl-2-pentanone 108-10-1 630 µg/L 1.67 µg/L 7 SW-846 8260 Acetone 67-64-1 1,400 µg/L 1.74 µg/L 7

Table 5.1. Detailed analyte list, analytical methods, and reporting requirements for K 31/K 33 groundwater sample a (cont.)

Project Action Method source Method Analyte CAS No. Reporting limit Holding time Limit SW-846 8260 Benzene 71-43-2 0.46 µg/L 1.67 µg/L 7 SW-846 8260 Bromodichloromethane 75-27-4 0.13 µg/L 0.333 µg/L 7 SW-846 8260 Bromoform 75-25-2 3.3 µg/L 0.333 µg/L 7 SW-846 8260 Bromomethane 74-83-9 0.75 µg/L 0.333 µg/L 7 SW-846 8260 Carbon disulfide 75-15-0 81 µg/L 1.67 µg/L 7 SW-846 8260 Carbon tetrachloride 56-23-5 0.46 µg/L 0.333 µg/L 7 SW-846 8260 Chlorobenzene 108-90-7 7.8 µg/L 0.333 µg/L 7 SW-846 8260 Chloroethane 75-00-3 2,100 µg/L 0.333 µg/L 7 SW-846 8260 Chloroform 67-66-3 0.22 µg/L 0.333 µg/L 7 SW-846 8260 Chloromethane 74-87-3 19 µg/L 0.333 µg/L 7 SW-846 8260 cis-1,2-Dichloroethene 156-59-2 3.6 µg/L 0.333 µg/L 7 SW-846 8260 cis-1,3-Dichloropropene 10061-01-5 3.6 µg/L 0.333 µg/L 7 SW-846 8260 Dibromochloromethane 124-48-1 0.87 µg/L 0.333 µg/L 7 SW-846 8260 Ethylbenzene 100-41-4 1.5 µg/L 0.333 µg/L 7 SW-846 8260 Methylene chloride 75-09-2 110 µg/L 1.67 µg/L 7 5-5 SW-846 8260 Styrene 100-42-5 120 µg/L 0.333 µg/L 7 SW-846 8260 Tetrachloroethene 127-18-4 4.1 µg/L 0.333 µg/L 7 SW-846 8260 Toluene 108-88-3 110 µg/L 0.333 µg/L 7 SW-846 8260 trans-1,2-Dichloroethene 156-60-5 6.8 µg/L 0.333 µg/L 7 SW-846 8260 trans-1,3-Dichloropropene 10061-02-6 0.47 µg/L 0.333 µg/L 7 SW-846 8260 Trichloroethene 79-01-6 0.28 µg/L 0.333 µg/L 7 SW-846 8260 Vinyl chloride 75-01-4 0.019 µg/L 0.333 µg/L 7 SW-846 8260 Xylenes (total)b 1330-20-7 19 µg/L 0.333 µg/L 7 a

The Project action limits are the respective RSLs for constituents that have them.

b Xylenes (total) may be reported as o-Xylene (CAS# 95-47-6) and m,p-Xylenes (CAS# 179601-23-1).AM20GAX = Laboratory-specific method used by Microseeps c

Nickel project action limit is a TDEC value for groundwater d

Using the screening level of 40 parts per trillion (ppt) to determine if PFOA and/or PFOS is present at a site and may warrant further attention. The Lifetime Drinking Water Health Advisories (HAs) of 70 ppt (combined or individually) will be used as the recommended Preliminary Remediation Goal (PRG) for groundwater that is a current or potential source of drinking water, where no state or tribal MCL or other applicable or relevant and appropriate requirements (ARARs) are available or sufficiently protective.

e Samples must be extracted within 14 days from collection and analyzed with 28 days from extraction.

µg/L = micrograms/liter mg/L = milligrams per liter ASTM = American Society for Testing and Materials ng/L = nanograms per liter CAS = Chemical Abstracts Service pCi/L = picocuries per liter Cr+6 = hexavalent chromium RAD = radiological/radiation EPA = U.S. Environmental Protection Agency Tc-99 = technetium-99 ISO = International Organization for Standardization U = uranium LCS = liquid scintillation counting

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6. INVESTIGATION-DERIVED WASTE Investigation-derived waste will be managed according to the waste management plan described in the East Tennessee Technology Park Site-Wide Residual Contamination Remedial Investigation Work Plan, Oak Ridge, Tennessee (DOE/OR/01-2154&D2). As previously discussed, additional wells from the original work plan will be sampled. Because the volume of waste generated will differ, the waste summary table (Table 6.1) has been revised.

Table 6.1. Revised waste summary for K-31/K-33 groundwater sampling activities Waste Estimated Planned Waste description Comments type quantity disposition Groundwater purge water NR 300 gal TSDRF Disposition depends upon the contaminant concentration Decontamination water NR 50 gal TSDRF Disposition depends upon the contaminant concentration Miscellaneous waste NR 0.5 cy TSDRF materials in contact with groundwater - sampling materials and PPE Non-contact miscellaneous NR 0.5 cy Y-12 waste materials - PPE Construction Landfill Miscellaneous trash and NR 0.5 cy ORR sanitary organic garbage (e.g., food landfill waste) cy = cubic yard gal = gallons NR = non-radiological ORR = Oak Ridge Reservation PPE = personal protective equipment TSDRF = treatment, storage, disposal, and recycling facility Y-12 = Y-12 National Security Complex 6-1

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7. REPORTS The additional groundwater data will be evaluated and reported with all data in the K-31/K-33 RI/FS report.

Concentration trends will be evaluated to determine the behavior of contaminants in the K-31/K-33 Area.

Data will be compared to EPAs National Primary Drinking Water Regulations MCLs or MCL-DC for identified contaminants of concern. Two screening levels are used - the full MCL/MCL-DC concentrations and an arbitrary value of 80% of the MCL/MCL-DC. The 80% level was selected to indicate the presence of contaminants the may be approaching the MCL/MCL-DC in the event that increasing concentration trends are occurring.

Mann-Kendall (M-K) trend evaluations using an application of Kendalls tau-b correlation of concentrations with time will also be conducted (Helsel 2005). Data are compartmentalized into a maximum time period of 10 years for longer duration trend evaluation and a secondary time period of five years to evaluate more recent trends. In addition to the M-K trend determinations for the 10-year and 5-year periods, trend evaluations are made using the annual maximum concentration values over the 10-year period. The reason for the additional trend evaluation is to determine if the frequently observed seasonal concentration fluctuations mask trends that appear to be present based on visual examination of contaminant history graphs. The M-K trend evaluation will be performed with at least six detected results per analyte to allow the method to attain a 90% confidence interval on the trend identification. For non-detect results, the detection limit is used in the M-K trend evaluations. However, non-detect results are treated as ties with detected results when non-detects exceeded the detected concentrations. In cases when the trend evaluation for the annual maximum concentration values indicate a trend different from that obtained for inclusion of all the data, both the trend from the full dataset and the trend from the annual maxima are included. If two trend determinations are not included in the significant trend columns, there is no difference between trends derived from annual maximum values versus the full dataset. Only contaminants with concentrations greater than or equal to 80% of the MCL/MCL-DC within the past 10 years will be presented.

Dixons outlier test is performed on the maximum concentration when there are fewer than 25 results per analyte. Rosners outlier test is performed on the maximum concentration when there are 25 or more results per analyte. Both Dixons and Rosners tests use the 0.05 significance level to determine statistical significance.

The validation for the all K-31/K-33 groundwater sampling (including sampling rounds at existing wells and the new piezometers) will be: 20% Level 4, 80% Level 3. No data usability report will be generated.

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7-2

8. PROJECT SCHEDULE The work described in this document is planned to start in October 2020 and end by October 2021. The initial sample collection event will start at risk prior to approval of this document.

The first and second round of sampling at all wells has been completed in October 2020 and January 2021.

The Federal Facility Agreement milestone date for delivery of the K-31/K-33 (RI/FS) was moved up to June 30, 2021, so not all rounds of sampling will be included in the K31-K33 RI/FS D1 document.

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9. REFERENCES DOE/OR/01-1297&D2. Phase 2 Remedial Investigation/Baseline Risk Assessment Report and Feasibility Study for the K-1070-C/D Classified Burial Ground at the Oak Ridge K-25 Site, Oak Ridge, Tennessee, 1995, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN.

DOE/OR/01-1455/V2&D1. Report on the Remedial Investigation of Bear Creek Valley at the Oak Ridge Y-12 Plant, Oak Ridge, Tennessee, Volume 2, 1996, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN.

DOE/OR/01-1468&V1&D1. Groundwater Remedial Site Evaluation Report for the Oak Ridge K-25 Site, Volume 1, Main Text, 1996, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN.

DOE/OR/01-02-1547&D3. Record of Decision for the Clinch River/Poplar Creek Operable Unit, 1997, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN.

DOE/OR/01-1612/V1&D2. East Tennessee Technology Park Site-Wide Remedial Investigation Work Plan, Volume 1, Main Text, 1998, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN.

DOE/OR/01-1778&D1. Remedial Investigation Report for East Tennessee Technology Park, Oak Ridge, Tennessee, 1999, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN.

DOE/OR/01-2154&D2. East Tennessee Technology Park Site-Wide Residual Contamination Remedial Investigation Work Plan, Oak Ridge, Tennessee, 2004, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN.

DOE/OR/01-2154&D2/A1/R1. Addendum to the East Tennessee Technology Park Site-Wide Residual Contamination Remedial Investigation Work Plan, Oak Ridge, Tennessee, 2011, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN.

DOE/OR/01-2224&D4. Remedial Design Report/Remedial Action Work Plan for Zone 2 Soils, Slabs, and Subsurface Structures, East Tennessee Technology Park, Oak Ridge, Tennessee, 2015, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN.

DOE/OR/01-2279&D3. Final Sitewide Remedial Investigation and Feasibility Study for the East Tennessee Technology Park, Oak Ridge, Tennessee, 2007, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN.

DOE/OR/01-2590&D1. Phased Construction Completion Report for Exposure Units Z2-04 and Z2-05 in Zone 2, East Tennessee Technology Park, Oak Ridge, Tennessee, 2012, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN.

DOE/OR/01-2677&D2. Supplemental Sampling and Analysis Plan for the East Tennessee Technology Park Sitewide Residual Contamination Remedial Investigation Oak Ridge, Tennessee, 2017, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN.

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DOE/OR/01-2677. Environmental Baseline Survey Report for the Proposed Title Transfer of the Former K-31 Area at the East Tennessee Technology Park, Oak Ridge, Tennessee, Final-Concurred, 2015, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN.

DOE/OR/01-2699&D2. Fiscal Year 2015 Phased Construction Completion Report for Exposure Unit Z2-06 in Zone 2, East Tennessee Technology Park, Oak Ridge, Tennessee, 2017, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN.

DOE/OR/01-2749&D1. Supplemental Sampling and Analysis Plan for the East Tennessee Technology Park Sitewide Residual Contamination Remedial Investigation, Oak Ridge, Tennessee, 2017, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN.

DOE/OR/01-2749&D1/A1. Addendum to the Supplemental Sampling and Analysis Plan for the East Tennessee Technology Park Sitewide Residual Contamination Remedial Investigation, Oak Ridge, Tennessee, 2019, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN.

DOE/OR/01-2765&D2. K-31/K-33 Area Groundwater Remedial Site Evaluation Report for the East Tennessee Technology Park, Oak Ridge, Tennessee, 2019, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN.

DOE/CSC-2513. Oak Ridge Reservation Annual Site Environmental Report 2019, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN.

DOE/OR/01-2749&D1/A1. Addendum to the Supplemental Sampling and Analysis Plan for the East Tennessee Technology Park Sitewide Residual Contamination Remedial Investigation, Oak Ridge, Tennessee, 2019, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN.

DOE/OR/01-2844&D1. 2020 Remediation Effectiveness Report for the U. S Department of Energy Oak Ridge Site, Oak Ridge, Tennessee. U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN EPA 1996. Soil Screening Guidance: Technical Background Document, 2nd ed., EPA/540/R-95/128, U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, Washington, D.C.

EPA 2007. Monitored Natural Attenuation of Inorganic Contaminants in Ground Water, Volume 1 -

Technical Basis for Assessment, EPA/600/R-07/139, U.S. Environmental Protection Agency, Office of Research and Development National Risk Management Research Laboratory, Ada, Oklahoma.

Lemiszki, P. J., Landes, J. D., Doolin, D. E., and Dunne, W. M. 1995. Rock mechanics testing of core from the Cambrian through Ordovician section in the Copper Creek and Whiteoak Mountain thrust sheets: Implications for aquifer mechanics on the Oak Ridge Reservation, Tennessee, Geol. Soc. Am.

Abstr. with Prog. 27:69.

Helsel, D. R. Nondetects and Data Analysis: Statistics for Censored Environmental Data, 2005, John Wiley

& Sons.

Sheppard, M. I., and Thibault, D. H. 1990. Default Soil Solid/Liquid Partition Coefficients for Four Major Soil Types: A Compendium, Health Phys. 59(4): 471482.

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UCOR-4049. Quality Assurance Project Plan for the Water Resources Restoration Program, U.S. Department of Energy, Oak Ridge Reservation, Oak Ridge, Tennessee, latest revision, UCOR LLC, Oak Ridge, TN.

UCOR-4160. Data Management Implementation Plan for the Water Resources Restoration Program, Oak Ridge, Tennessee, latest revision, UCOR LLC, Oak Ridge, TN.

UCOR-4587/R6. Sampling and Analysis Plan for the Water Resources Restoration Program for Fiscal Year 2021 Oak Ridge Reservation, Oak Ridge, Tennessee, 2020, UCOR, an Amentum-led partnership with Jacobs, Oak Ridge, TN.

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APPENDIX A.

UNIFORM FEDERAL POLICY QAPP CHECKLIST

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ETTP Addendum 2 Supplemental K-31/K-33 SAP/QAPP Title and Approval Page Site Name/Project Name: East Tennessee Technology Park/K-31/K-33 Area Site Location: Oak Ridge, Tennessee Revision Number: DOE/OR/01 2749&D1/A2/R1 Date: May 2021 Document

Title:

Addendum 2 to the Supplemental Sampling and Analysis Plan for the East Tennessee Technology Park Sitewide Residual Contamination Remedial Investigation K-31/K-33 Area, Oak Ridge, Tennessee, (DOE/OR/01 2749&D1/A2/R2)

U.S. Department of Energy, Office of Environmental Management, Oak Ridge, Tennessee Lead Organization Lead Organizations Project Manager*

James Daffron ______________________________________

DOE OREM Signature/Date

• DOE will ensure that the requirements of this SAP/QAPP are contractual requirements for the Investigative Organization.

U.S. Environmental Protection Agency Approval Signatures:

Craig VanTrees Remedial Project Manager ______________________________________

Signature/Date Cathy Amoroso-Chief Restoration & DOE Coordination ______________________________________

Section, Superfund & Emergency Management Signature/Date Page 1 of 24

USEPA REGION 4 SUPERFUND DIVISION FINAL Uniform Federal Policy SAP/QAPP CHECKLIST Element Meets Requirements QAPP Approval Page Worksheet 1 1:8] Yes

• No

• Approval page - signatories identified on approval page.

Title of SAP and QAPP Worksheet 1 1:8] Yes

• No

• Addendum 2 to the Supplemental Sampling and Analysis Plan for the East Tennessee Technology Park Sitewide Residual Contamination Remedial Investigation K-31/K-33 Area, Oak Ridge, Tennessee, January 2021, (DOE/OR/01-2749&D1/A2; Addendum 2 of the Supplemental SAP).

• Quality Assurance Project Plan for the Water Resources Restoration Program, U.S.

Department of Energy, Oak Ridge Reservation, Oak Ridge, Tennessee, September 2019, (UCOR-4049/R6; WRRP QAPP).

Organizations Name: The name of the Lead Organization, the name of the organization 1:8] Yes

• No

• U.S. Department of Energy (DOE) is the lead preparing the SAP, and the name of the organization. DOEs prime contractor organization conducting the project (if different [currently UCOR LLC] is the investigative from preparer). For Federal Facilities, the Lead organization.

Organization is the Facility (DOD, DOE).

Worksheet 1 Dated Signatures: Investigative Organizations Project Manager, Investigative Organizations 1:8] Yes

• No

• Page 1 of this Worksheet.

QA Officer, and Lead Organizations Project Manager.

Worksheet 1 Date and Signature of USEPA Quality Assurance Manager or Designated Approving Official 1:8] Yes

• No

• EPA approving official identified on the Worksheet 1 Addendum 2 to the Supplemental SAP Checklist Title and Approval Page.

SAP Identifying Information Worksheet 2 1:8] Yes

• No

• Identifying information on the Addendum 2 to the Supplemental SAP Checklist Title and Approval Page.

Distribution List: Including Addresses of all entities or agencies requiring copies of the SAP 1:8] Yes

• No

• The Addendum 2 to the Supplemental SAP is Worksheet 3 distributed and maintained as a primary document by DOE in accordance with the Federal Facility Agreement for the Oak Ridge Reservation (DOE/OR-1014).

Page 2 of 24

Element Meets Requirements Project Personnel Sign-Off Sheet: Identifies key project personnel and specifies technical

~ Yes

• No

• Project personnel participate in periodic ETTP disciplines. Remedial Action Project Team meetings as Worksheet 4 verified in meeting minutes.

Project Organizational Chart: Organization chart provided: Depicts lines of authority,

~ Yes

• No

• The Addendum 2 to the Supplemental SAP independence (of QA manager), and reporting incorporates by reference WRRP QAPP.

responsibilities. Org- chart also contains entries for all agencies, contractors, and individuals

• Section 2.0, Project Organization, of the responsible for performing SAP preparation, WRRP QAPP describes project organization sample collection, laboratory analysis, data and responsibilities; defines individuals verification, review and validation, data quality responsible for sample collection, analysis, assessment; and project oversight responsibilities. data reporting, verification, and validation.

Worksheet 5

• Figure 1 of the WRRP QAPP shows the organization, interfaces, and support; this figure does not address all agencies; however, the essential "staff" is referenced.

Communication Pathways: Details their roles/responsibilities and details communication

~ Yes

• No

• Section 2.0, Project Organization, of the pathways. WRRP QAPP describes project organization Worksheet 6 and responsibilities.

Personnel Responsibilities and Qualifications Table

~ Yes

• No

• Section 2.0, Project Organization, of the Worksheet 7 WRRP QAPP describes project organization and responsibilities.

• Section 16.0, Training, of the WRRP QAPP describes qualifications and training.

Special Training Requirements and Special Certifications Worksheet 8 Identifies how training needs are determined and lists all training requirements for the project.

~ Yes

• No

• Section 16.0, Training, of the WRRP QAPP Specifies whether certain professionals require a describes qualifications and training.

license or certification to perform duties as required by federal or state laws.

Worksheet 8 Project Scoping Session Participants Worksheet 9

~ Yes

• No

• Section 2.0, Site History, Table 2.1 of the Addendum 2 to the Supplemental SAP provides a timeline and multiple references of meetings and DQO workshops which guided groundwater investigation addressing the K-31/K-33 Area.

Problem Definition/Background Worksheet 10 Page 3 of 24

Element Meets Requirements Clearly states the particular environmental problem to be solved, decision to be made, or

~ Yes

• No

• Section 2.0, Site History, and Table 2.1 of the outcome to be achieved. Include sufficient Addendum 2 to the Supplemental SAP background information to provide a historical, provides a timeline of groundwater scientific, and regulatory perspective for this investigation, site history, removal actions, and particular project. remedial actions of the K-31/K-33 Area.

Worksheet 10

• Section 3.0, Data Quality Objectives, of the Addendum 2 to the Supplemental SAP provides key aspects of the conceptual site model (CSM).

• Section 6.4, K-31/K-33 Geographic Area, of the Final Sitewide Remedial Investigation and Feasibility Study for the East Tennessee Technology Park, Oak Ridge, Tennessee, November 2007 (DOE/OR/01-2279&D3; Sitewide RI/FS) provides an extensive site history of the K-31/K-33 Area.

• Section 6.4.1, Conceptual Site Model for the K-31/K-33 Geographic Area, of the Sitewide RI/FS discusses the CSM.

Provides historical and background information concerning prior environmental investigations or

~ Yes

• No

• Section 2.0, Site History, and Table 2.1 of the assessments performed at the site. Discusses the Addendum 2 to the Supplemental SAP, data collected from these prior investigations and provides a summary of environmental identifies any additional information that may be investigations performed.

contained in computer databases (secondary data), etc.

• Section 6.4, K-31/K-33 Geographic Area,, of the Sitewide RI/FS discusses previous Worksheet 10 investigations.

• Section 6.4, K-31/K-33 Geographic Area, of the Sitewide RI/FS includes groundwater monitoring data.

Project Quality Objectives/Systematic Planning Process Statements Worksheet 11 Provides the Data Quality Objectives in accordance and compliance with EPAs Data

~ Yes

• No

• Section 3.2, Data Quality Objectives for the Quality Objective Process (EPA-QA/G-4) Supplemental Sampling, of the Addendum 2 to document. Lists the seven steps of the DQO the Supplemental SAP provides steps 1 process and provides the project-specific through 7 of the DQO process.

information pertaining to each of these steps.

Applies a systematic planning process to the

• Section 3.0, DQO, of the WRRP QAPP, project study undertaken. Provides the qualitative discusses data collection and analysis and quantitative data quality objectives for all developed as DQOs for this project.

aspects of the project. Must provide clearly

• Section 6.4, K-31/K-33 Geographic Area, of delineated project objectives such as determining the Sitewide RI/FS provides a detailed the presence/absence of potential contaminants, nature and extent of contamination, determining Page 4 of 24

Element Meets Requirements whether human health is affected. Must provide a discussion of the potential sources of list of decisions and alternative actions contaminants to groundwater.

(remediation, removal, further assessments, no

• Section 7.0, Baseline Human Health Risk further action, etc.). Assessment, of the Sitewide RI/FS provides Worksheet 11 the baseline human health risk assessment (BHHRA) that was prepared for the Final Sitewide RI/FS (DOE/OR/01-2279&D2; DOE 2007).

Measurement Performance Criteria Table Worksheet 12 Identifies the data quality indicators, measurement performance criteria, and QC 1:8] Yes

• No

• Section 4.3 Quality Control Duplicate sample and/or activity used to assess the Samples, and Section 4.4, Quality Control Trip measurement performance for both the sampling Blanks Samples, of the Addendum 2 to the and analytical measurement systems. Supplemental SAP, provides frequency of Worksheet 12 collection.

• Section 10.1, Field QC Checks, of the WRRP QAPP, identified the field Quality Control (QC) samples to be collected.

• Table 3 of the WRRP QAPP provides data quality indicators for measurement performance criteria of precision, accuracy, and completeness.

• Section 7.0, Calibration Procedures and Frequency, of the WRRP QAPP, describes required laboratory and field instrument calibration.

• The Data Management Implementation Plan (UCOR-4160/R0; DMIP) serves as the project level plan for managing all data collected by the project.

• The Analytical Master Specification (AMS),

provides the range of performance. If judged to have tighter limits, a laboratory can have their own specific performance criteria.

• Performance criteria provided in laboratory test method.

Secondary Data Criteria and Limitations Table Worksheet 13 Identifies the type and frequency of non-direct measurement techniques for the project (for 1:8] Yes

• No

• The WRRP uses only primary data for the computer databases, literature searches, etc.). Worksheet 13 ETTP watershed, for which Worksheet 13 monitoring is only being performed by the prime contractor to DOE and associated Page 5 of 24

Element Meets Requirements subcontractors. Thus, there is no data identified as secondary, meaning performed by other DOE Oak Ridge Reservation prime contractors like UT-Battelle, in the ETTP CMP (DOE/OR/Ol-2477&D4). The current DOE prime contractor over ETTP is the URS l CH2M Oak Ridge LLC (UCOR).

• Historical data from previous DOE prime contractors are used for background information and determining trends for the ETTP watershed and are not considered secondary data. The contractor prior to UCOR was the Bechtel Jacobs Company LLC (BJC) and Lockheed Martin Energy Systems was the prime contractor before BJC.

• Table B of the ETTP CMP (DOE/OR/0l-2477&D4), Sampling Program column identifies the monitoring conducted under the prime contractor programs.

Identifies the type and frequency of non-detect measurement techniques for the project (for 1:8] Yes

• No

• There is no secondary monitoring for the ETTP computer databases, literature searches, etc.) watershed. See the explanation for Worksheet Worksheet 13 13 in the first entry above.

Clearly identified and describes the limitations of such data.

1:8] Yes

• No

• There is no secondary monitoring for the ETTP Worksheet 13 watershed. See the explanation for Worksheet 13 in the first entry above.

Discusses the rationale for using this data and explains its relevance to the project.

1:8] Yes

• No

• There is no secondary monitoring for the ETTP Worksheet 13 watershed. See the explanation for Worksheet 13 in the first entry above.

Specifies how limitations in this data will be communicated to all end data users and 1:8] Yes

• No

• There is no secondary monitoring for the ETTP stakeholders. watershed. See the explanation for Worksheet Worksheet 13 13 in the first entry above.

Summary of Project Tasks Worksheet 14 Provides a summary of all work to be performed, products to be produced, data and management 1:8] Yes

• No

• Section 4.0, Sampling and Analysis Approach, assessment. Lists the actual measurements to be of the Addendum 2 to the Supplemental SAP, made: Including in-situ field measurements, fixed provides a summary of sampling and laboratory measurements, or any other type of temporary piezometer installation to be information collected as part of the project. performed.

Worksheet 14 Page 6 of 24

Element Meets Requirements

• Section 4.1, Proposed Sampling and Analysis, of the Addendum 2 to the Supplemental SAP identifies sampling locations.

• Section 4.1.1, Quarterly Sampling, of the Addendum 2 to the Supplement SAP provides a list of water quality parameters to be collected under this SAP.

• Section 5.0, Sample Collection Method, of the Addendum 2 to the Supplemental SAP, provides the sampling methods and Section 5.1.2 provides the analytical parameters.

• Section 7.0, Reports, of the Addendum 2 to the Supplemental SAP, describes that the additional groundwater data will be evaluated and reported with all data in the K-31/K-33 RI/FS report and that concentration trends will also be evaluated to determine the behavior of contaminants in the K-31/K-33 Area.

Reference Limits and Evaluation Table Worksheet 15 Cites applicable regulatory standards or criteria such as action limits, ARARs, PRGs, MCLs, risk

~ Yes

• No

• Section 4.1, Proposed Sampling and Analysis, assessment screening levels, etc. Must provide the and Table 4.1, of the Addendum 2 to the actual numerical criteria for the above items. Supplemental SAP provides analysis of Provides all regulatory standards/criteria as part groundwater sampling results summary and of DQO process (action limits, ARARs, PRGs, wells proposed for further sampling including MCLs, etc.) on an analyte by analyte basis. MCLs and exceedances.

Worksheet 15

• Section 5.1, Groundwater, Table 5.1 of the Addendum 2 to the Supplemental SAP presents the reporting limits for the groundwater samples.

• Section 6.4, K-31/K-33 Geographic Area, of the Sitewide RI/FS provides analysis of groundwater sampling results summary and includes MCLs and wells with exceedances.

• Section 3.0, Data Quality Objectives, of the Addendum 2 to the Supplemental SAP, Table 3.2 indicates constituents exceeding their respective MCLs (includes both federal and State of Tennessee drinking water MCLs) and Table 3.1 provides summary statistics for the individual wells with groundwater concentrations exceeding MCLs; Figure 6.50 in the Sitewide RI/FS (DOE/OR/01-2279&D2) provides an illustration of the distribution of MCL exceedances in the K-31/K-33 Area at that time.

Page 7 of 24

Element Meets Requirements

• Section 6.4.3.2, Nature and extent of groundwater contamination in the K-31 and K-33 building area, Table 6.37 of the Sitewide RI/FS compares groundwater results to MCLs.

• Performance/compliance levels for CERCLA decisions are codified in decision documents (RODs, AMs, etc.) and are flowed through monitoring plans and the WRRP QAPP to the analytical program. As state and national standards are modified, the analytical project quantitation limits are adjusted based on stipulated criteria and applicable or relevant and appropriate requirements (ARARs).

During 5- year reviews, the re-evaluation of risk includes updating toxicity slope factors and risk-based criteria which can also affect analytical requirements and comparative criteria.

Provides a list of all the critical contaminants/analytes along with their respective

~ Yes

• No

• Section 5.1.2, Analytical Parameters, and detection limit requirements (for chemical Table 5.1 of the Addendum 2 to the parameters) and quantitation limit. Supplement SAP provides a detailed analyte Worksheet 15 list, analytical methods, and reporting requirements for K 31/K 33 groundwater samples.

• Appendix D, Analytical Parameters Group Tables and Typical Bottle List for Sample Collection, of the WRRP QAPP, provides analytical method for parameter group/analyte with the corresponding project quantitation limit.

• Laboratory SOW - provides project/scope of work analytes/contaminants for analysis.

• Laboratory Chain-of-Custody forms.

• Section 8.2, Laboratory Analytical Methods, of the WRRP QAPP.

Project Schedule\Timeline Table Worksheet 16 Provides work schedule for all tasks including report preparation, response to comments, etc.

~ Yes

• No

• Section 8.0, Project Schedule, of the Worksheet 16 Addendum 2 of the Supplement SAP identifies the schedule of this SAPs activities.

• Section 7.0, Reports, of the Addendum 2 to the Supplemental SAP, describes that the additional groundwater data will be evaluated and reported with all data in the K-31/K-33 Page 8 of 24

Element Meets Requirements RI/FS report and that concentration trends will also be evaluated to determine the behavior of contaminants in the K-31/K-33 Area.

• The Federal Facility Agreement (FFA) stipulates the report preparation/submittal schedule, which includes a process for review, comment response, and report revision.

Identifies all required reports, records, data reports, quality assurance reports/documents.

1:8] Yes

• No

• Section 7.0, Reports, of the Addendum 2 to the Worksheet 16 Supplemental SAP, describes that the additional groundwater data will be evaluated and reported with all data in the K-31/K-33 RI/FS report and that concentration trends will also be evaluated to determine the behavior of contaminants in the K-31/K-33 Area.

• Sampling Personnel are responsible for documenting, recording, retention, maintenance, and disposition of collected field data with transmittal to Record Management.

• Sample Management Office (SMO) activities/responsibilities for records are identified in Table 1 of the DMIP (UCOR-4160/R0). This listing provides the various records generated after sample collection, e.g.,

chain-of-custody, electronic data deliverables, verification and validation of analytical results.

• QA Reports:

Monthly Issue and Corrective Action Status Report, Training Matrix Status Report, Assessment Records, Corrective Action Plans and Action Closures, and Environmental Inspections, and Data Reviews and Validation.

Sampling Design and Rationale Worksheet 17 Provides design of the sampling/collection network.

1:8] Yes

• No

• Section 3.2, Data Quality Objectives for the Worksheet 17 Supplement Sampling, of the Addendum 2 to the Supplement SAP, focuses on the main questions that need to be answered in order to produce the RI/FS. Table 3.4 summarizes this focused DQO effort. The summary presents an overview of the designed sampling network.

Page 9 of 24

Element Meets Requirements

• Section 5.1, Groundwater, of the Addendum 2 of the Supplemental SAP, discusses the sample locations and Table 4.3 describes the analyses to be performed and Table 4.2 shows sample location, well construction details, water column, and presence/absence of dedicated micropurge pumps.

Provides an extensive discussion regarding the rationale for the sampling design. (This also

~ Yes

• No

• Section 1.0, Introduction, of the Addendum 2 includes a discussion regarding the rationale and to the Supplement SAP, summarizes the relevance of the analytical program). importance of this supplemental sampling Worksheet 17 event.

• Section 3.2, Data Quality Objectives for the Supplement Sampling, of the Addendum 2 to the Supplement SAP, focuses on the main questions that need to be answered in order to produce the RI/FS. Tables 3.4 and 3.5 summarize this focused DQO effort. The summary presents an overview of the designed sampling network.

• Section 5.1, Groundwater, of the Addendum 2 of the Supplemental SAP, discusses the sample locations and Table 4.3 describes the analyses to be performed and Tables 4.1 and 4.2 show the sampling locations, rationale, MCL exceedances, well construction details, water column, and presence/absence of dedicated micropurge pumps.

Sampling locations and Methods/SOP Requirements Table Worksheet 18 Provides a table with type and number of samples required for collection such as surface,

~ Yes

• No

• Section 3.2, Data Quality Objectives for the subsurface, or groundwater. Supplemental Sampling, of the Addendum 2 to Worksheet 18 the Supplement SAP, focuses on the main questions that need to be answered in order to produce the RI/FS. Tables 3.4 and 3.5 summarize this focused DQO effort. The summary presents an overview of the designed sampling network.

• Section 5.1, Groundwater, of the Addendum 2 of the Supplemental SAP, discusses the sample locations and Tables 4.4 and 4.5 describe the analyses to be performed, and Table 4.2 shows well construction details, water column, and presence/absence of dedicated micropurge pumps.

Page 10 of 24

Element Meets Requirements Provides maps or diagrams with sample locations/collection locations and provides table

~ Yes

• No

• Section 3.2, Data Quality Objectives for the with frequency of sampling events. Supplement Sampling, of the Addendum 2 to Worksheet 18 the Supplemental SAP, focuses on the main questions that need to be answered in order to produce the RI/FS. Tables 3.4 and 3.5 summarize this focused DQO effort. The summary presents an overview of the designed sampling network.

• Section 4.0, Sampling and Analysis Approach, of the Addendum 2 to the Supplemental SAP, discusses sample locations, Figure 4.1 illustrates proposed monitoring wells selected for additional sampling, and Table 5.1 lists the analyses to be performed at each sample location.

Provides the sample matrices slated for collection in the sample table (surface soil, subsurface soil,

~ Yes

• No

• Section 3.2, Data Quality Objectives for the sediment, surface water, groundwater samples, Supplement Sampling, of the Addendum 2 to etc.). the Supplemental SAP, focuses on the main Worksheet 18 questions that need to be answered in order to produce the RI/FS. Tables 3.4 and 3.5 summarize this focused DQO effort. The summary presents an overview of the designed sampling network.

• Section 4.0, Sampling and Analysis Approach, of the Addendum 2 to the Supplemental SAP, discusses sample locations, Figure 4.1 illustrates proposed monitoring wells selected for additional sampling, and Table 5.1 lists the analyses to be performed at each sample location.

Analytical SOP Requirements Table Worksheet 19 Clearly identifies the extraction, digestion, analytical methodologies (provides the actual

~ Yes

• No

• Section 5.0, Sample Collection Method, Table method numbers) to be followed (includes all 5.1, of the Addendum 2 of the Supplemental relevant options or modifications required), SAP provides a detailed analyte list, analytical identifies the required instrumentation. Include methods, and reporting requirements for copies of the SOPs as attachments or reference in groundwater samples.

the SAP.

• Section 8.2, Laboratory Analytical Methods, of Worksheet 19 the WRRP QAPP provides a list of reference documents for analytical methods and procedures employed by the laboratory and are based on accepted EPA methods. Copies of the analytical SOPs can be made available upon request as they are laboratory specific.

Page 11 of 24

Element Meets Requirements Provides table listing sample container requirements and preparation requirements for

~ Yes

• No

• Appendix D, Analytical Parameters Group these containers (if provided by laboratory, Tables and Typical Bottle List for Sample clearly states such). Collection, of the WRRP QAPP, provides Worksheet 19 analytical method for parameter group/analyte with the corresponding project quantitation limit.

• Section 4.0, Sampling and Analysis Approach, of the Addendum 2 to the Supplemental SAP, discusses sample locations, Figure 4.1 illustrates proposed monitoring wells selected for additional sampling, and Table 5.1 lists the analyses to be performed at each sample location.

Provides table listing sample preservation requirements (for chemical parameters) and

~ Yes

• No

• Section 5.0, Sample Collection Method, Table holding time criteria (where applicable). 5.1, of the Addendum 2 of the Supplemental Worksheet 19 SAP, lists holding times.

• Appendix D, Analytical Parameters Group Tables and Typical Bottle List for Sample Collection, of the WRRP QAPP, provides analytical method for parameter group/analyte holding times, and preservation.

• Section 5.2, Sample Container and Holding Time, of the WRRP QAPP, references holding time and preservation is available on the chain of custody forms to communicate to sampling personnel.

Field Quality Control Sample Summary Table Worksheet 20

• Yes ~ No

• Section 10.0, QC Checks, of the WRRP QAPP discusses types and frequency.

• Sections 4.3, Quality Control Duplicate Samples, and 4.4, Quality Control Trip Blank Samples, Section 5.0, Sample Collection Methods (duplicate, equipment rinse blanks, and trip blanks), of the Addendum 2 of the Supplemental SAP, discusses type the frequency of QC samples to be collected.

Project Sampling SOP Reference Worksheet 21 Identifies all instruments/equipment needed to conduct project.

~ Yes *

• Work packages.

No Worksheet 21

• Section 5.0, Sample Collection Procedures, of the WRRP QAPP reference Appendix C, Sampling Personnels field procedures. Each Page 12 of 24

Element Meets Requirements procedure defines the equipment and instruments needed for the sampling activity.

• An Inventory List of equipment with make and model is managed by the subcontractors Calibration Coordinator.

• Government Furnished Equipment (GFE) list contains field equipment used on the program and also include make and model.

• Section 7.0, Calibration Procedures and Frequency, Table 3, of the WRRP QAPP provides a list of typical field instruments.

• Logbooks list field equipment.

Provides the required field sample collection procedures, protocols and methods.

~ Yes

• No

• Section 5.0, Sample Collection Procedures, of Worksheet 21 the WRRP QAPP reference Appendix C, Sampling Personnels field procedures. Each procedure defines the equipment and instruments needed for the sampling activity.

Provides a list of sampling/collection equipment (including make and model of equipment).

~ Yes

• No

• Section 5.0, Sample Collection Procedures, of Worksheet 21 the WRRP QAPP reference Appendix C, Sampling Personnels field procedures. Each procedure defines the equipment and instruments needed for the sampling activity.

• Work packages.

• Inventory Management Program. An Inventory List of equipment with make and model is managed by the subcontractors Calibration Coordinator.

• Government Furnished Equipment (GFE) list contains field equipment used on the program and also include make and model.

• Logbooks.

Identifies on-site support facilities that are available to field staff.

• Yes

• N/A.

~ No Worksheet 21 Identifies key study personnel in charge of or overseeing sampling/collection activities.

~ Yes

• No

• Section 2.0, Project Organization, of the Worksheet 21 WRRP QAPP identifies key project personnel.

Describes equipment decontamination procedures and requirements. Discusses whether sampling

~ Yes *

• Section 5.4, Decontamination of Equipment equipment is dedicated or non-dedicated. and Devices, of the WRRP QAPP.

Worksheet 21

• Section 5.0, Sample Collection Procedures, of the WRRP QAPP Appendix C, references Page 13 of 24

Element Meets Requirements PROC-ES-2702, Decontamination of Equipment and Sample Devices.

• Government Furnished Equipment (GFE) list identifies dedicated equipment by site name.

Field Equipment Calibration, Maintenance, Testing and Inspection Tables Worksheet 22 Provides a list of all in-situ testing instruments and field equipment.

~ Yes

• No

• Government Furnished Equipment (GFE) list Worksheet 22 provides a list of field equipment.

• An Inventory List of in-situ groundwater level trolls is managed by the Calibration Coordinator.

• Section 7.0, Calibration Procedures and Frequency, Table 3, of the WRRP QAPP provides a list of typical field instruments.

Provides the technical criteria by which the field instruments or sampling equipment is checked for

~ Yes *

• Section 7.0, Calibration Procedures and acceptable performance. Frequency, of the WRRP QAPP.

Worksheet 22

• Section 12.0, Preventive Maintenance Procedures/Schedules, of the WRRP QAPP.

Provides a comprehensive list of the supplies required for the project.

• Yes ~ No

• N/A. UCOR does not maintain a Worksheet 22 comprehensive list of consumables used by the sampling or analytical subcontractors.

Provides the acceptance criteria for consumable items, instruments, and equipment.

~ Yes

• No

• Section 11.2, Subcontractor Assessments, of Worksheet 22 the WRRP QAPP, discusses the appropriate level of receipt inspection and reporting for instruments and equipment.

Describes equipment and corrective maintenance practices to ensure that on-site equipment or

~ Yes

• No

• Section 7.0, Calibration Procedures and instruments are performing within the required Frequency, of the WRRP QAPP.

specifications.

• Section 12.0, Preventive Maintenance Worksheet 22 Procedures/Schedules, of the WRRP QAPP.

• Sampling Personnels daily field calibration log and manufacturer instructions for equipment calibration.

Identifies the availability and location of spare parts.

• Yes ~ No

• N/A. Spare parts are purchased on an as-Worksheet 22 needed basis. Consumables are kept on hand, but spare parts are not generally part of the standard inventory.

Page 14 of 24

Element Meets Requirements Analytical SOP Reference Table Worksheet 23 List all SOPs that will be used to perform on-site or off-site analysis. Indicate whether the 1:8] Yes

• No

• Section 5.0, Sample Collection Method, of the procedure produces screening or definitive data. Addendum 2 of the Supplemental SAP refers Sequentially number analytical SOP references in to the WRRP QAPP for all SOPs.

the Reference Number column. Include copies of the SOPs as attachments or reference in the SAP.

• Section 8.2, Laboratory Analytical Methods, of The reference number can be used throughout the the WRRP QAPP provides a list of reference SAP to refer to a specific SOP. documents for analytical methods and procedures employed by the laboratory and are Worksheet 23 based on accepted EPA methods. Copies of the analytical SOPs can be made available upon request as they are laboratory specific.

• Section 5.0, Sample Collection Procedures, of the WRRP QAPP, refers Appendix C which provides a lists of subcontractor procedures related to the collection of environmental media.

• Appendix D, of the WRRP QAPP list specific analytical methods and project quantitation level goals (provided as an example) for samples obtained at ETTP.

Analytical Instrument Calibration Table Worksheet 24 Identifies all equipment requiring calibration and discusses the frequency of calibration 1:8] Yes

• No

• Section 7.4, Calibration Records, of the Worksheet 24 WRRP QAPP and Section 5.5 Calibration Requirements, of the Consolidated Quality Systems Manual (QSM) for Environmental Laboratories, the AMS, or the specific analytical/test method stipulate calibration requirements, frequency, and acceptance criteria.

• Section 7.2, Laboratory Instrument Calibration Procedures and Frequency, of the WRRP QAPP, discusses laboratory instrument calibration.

• The QSM requires the laboratory to have SOPs for laboratory equipment maintenance.

• Laboratory SOPs.

Identifies the calibration requirements for each instrument requiring calibration. (For fixed 1:8] Yes

• No

• Laboratory method-specific or SOP identifies laboratory this is most likely to be in the SOPs or any required calibration.

QA manual).

• Section 7.4, Calibration Records, of the Worksheet 24 WRRP QAPP and Section 5.5.13.1 Calibration Page 15 of 24

Element Meets Requirements Requirements, of the QSM also address calibration for measuring and test equipment (M&TE).

Provides the calibration requirements and calibration acceptance criteria for each type of

~ Yes

• No

• Laboratory method-specific or SOP identifies equipment or instrument. (Again for the off-site any required calibration.

laboratory this information will reside in the method-specific SOPs and the QA manual).

• Required calibrations flow down from QSM to AMS to laboratory method-specific or SOPs.

Worksheet 24 Identifies the type of documentation required for calibrations and instrument checks and discusses

~ Yes

• No

• Required calibrations flow down from QSM to how calibrations are traced back to specific AMS to laboratory method-specific or SOPs instruments for each analytical parameter. (Once which identifies the type of documentation for again for the off-site laboratory this information any required calibration and how it is traced will reside in the method-specific SOPs and the back to the instruments used for those QA manual). calibrations.

Worksheet 24 Analytical Instrument and Equipment Maintenance, Testing, and inspection Table Worksheet 25 Identifies all analytical instrumentation that requires maintenance, testing, and inspection and

~ Yes

• No

• Section 5.0, Technical Requirements of the provide the SOP reference number for each. In QSM addition, document the frequency, acceptance criteria, and corrective action requirements.

• Section 7.2, Laboratory Instrument Calibration Procedures and Frequency, of the Worksheet 25 WRRP QAPP, discusses required calibration of laboratory M&TE.

Provides a comprehensive list of the consumables such as, solvents, reagents, buffer solutions and

• Yes ~ No

• N/A. UCOR does not maintain a other consumables or supplies required for the comprehensive list of consumables used by the project. sampling team or analytical subcontractors.

Worksheet 25 Provides the acceptance criteria for each of these items.

• • N/A.

Yes ~ No Worksheet 25 Identifies those individual(s) responsible for checking/inspecting supplies and consumables.

• • N/A.

Yes ~ No Worksheet 25 Sample Handling Worksheet 26 Provides a detailed description of the procedures for post sample handling (once the sample has

~ Yes

• No

• Section 6.0, Sample Custody, of the WRRP been collected). QAPP discusses sample handling and Worksheet 26 Page 16 of 24

Element Meets Requirements references PROC-ES-2708, Chain of Custody Protocol for Environmental Sampling.

• Section 5.3, Sample Packaging and Preservation, of the WRRP QAPP discusses sample handling of samples prior to shipment.

• Appendix C of the WRRP QAPP provides a list of relevant sampling procedures.

• PROC-ES-2706, Shipping Samples, Dangerous Goods and Non-Bulk Hazardous Materials.

• PROC-TR-9503, Shipping Samples form a Company Site.

Sample Custody Requirements Worksheet 27 Provides a detailed description of the chain-of-custody procedures.

~ Yes

• No

• Section 6.0, Sample Custody, of the WRRP Worksheet 27 QAPP discusses sample custody and references PROC-ES-2708, Chain of Custody Protocol for Environmental Sampling.

QC Sample Table Worksheet 28 Identifies the type, number and frequency of procedures and frequency of QA/QC sample

~ Yes

• No

• Section 10.0, QC Checks, of the WRRP QAPP collection along with the required QC statistically discusses types and frequency.

derived limits for each analyte (for spike samples, internal standards, and surrogate spikes).

• Sections 4.3, Quality Control Duplicate Samples, and 4.4, Quality Control Trip Blank Worksheet 28 Samples, Section 5.0, Sample Collection Methods (duplicate, equipment rinse blanks, and trip blanks), of the Addendum 2 of the Supplemental SAP, discusses type the frequency of QC samples to be collected.

• AMS provides the method-specific or laboratory performance SOPs.

Provides the statistical equations for accuracy, precision, and comparability. Specifies the

~ Yes

• No

• Specifications to the analytical laboratories.

acceptance criteria for these measurements.

• Section 13.0, Specific Routine Procedures, of Worksheet 28 the WRRP QAPP discusses statistical equations for accuracy, precision, and comparability.

Project Documents and Records Table Worksheet 29 Provides a comprehensive list of the documents and records required for this project (including

~ Yes

• No raw data, field logs, audit reports, QA reports, progress or status reports, analytical data reports, Page 17 of 24

Element Meets Requirements data validation reports/data quality assessments

• Section 7.0, Reports, of the Addendum 2 of the reports.) Supplement SAP, describes the evaluation of Worksheet 29 groundwater data future reporting.

• Section 17.0, QA Reports to Management, of the WRRP QAPP.

• DMIP (UCOR-4160/R0) Section 3.0, Data and Data Records Transmittals.

• Section 15.0, Records and Document Control, of the WRRP QAPP.

• Sample Management Office procedures:

• PROC-ES-5002, Oak Ridge Sample Management Office Laboratory Contract Compliance Verification and Invoicing.

• PROC-ES-5005, Oak Ridge Sample Management Office Laboratory Data Validation for Inorganic and Organic Analyses.

• PROC-ES-5006, Oak Ridge Sample Management Office Laboratory Data Validation for Radiochemical Analyses.

Describes the record-keeping, archival and retrieval requirements for hard-copy and

~ Yes

• No

• Section 15.0, Records and Document Control, electronic information produced during the course of the WRRP QAPP.

of the project.

• Section 1.3, 2.1 through 2.10, and 3.0 of the Worksheet 29 DMIP (UCOR-4160/R0).

Provides assessment checklists or other standardized forms in an appendix to the SAP.

~ Yes

• No

• Section 5.0, Figure 2, Laboratory COC Worksheet 29 (example) of the WRRP QAPP.

• Section 15.0, Figure 3, Document Management Control Worksheet, of the WRRP QAPP.

Provides the retention time and location of study records, reports, and formal documents.

~ Yes

• No

• Section 15.2, Records Retention, of the WRRP Worksheet 29 QAPP.

• Section 15.3, Records Storage, of the WRRP QAPP.

• Section 3.0, Data and Data Records Transmittals, of the DMIP (UCOR-4160/R0).

Describes data handling equipment and procedures used to process, compile and analyze

~ Yes

• No

• DMIP (UCOR-4160/R0).

data (provides a complete list of computer hardware and software needs) - Specifies whether

• Project Environmental Measurements Systems computer databases will have restricted access or (PEMS) User Manual.

will be password protected. Discusses how the

• PROC-ES-2204, Hydrologic Data Analysis accuracy of computer databases is assured. and Summarization.

Page 18 of 24

Element Meets Requirements Worksheet 29

• PROC-ES-2200, Hydrologic Surface Water Flow Measurements.

Database restricted access:

• PEMS and Tracker Application Security Specifications and Controls (ASSC) in the Server Asset Management and Official Applications (SAMOA) System.

Section 2.1 - Types of users.

Section 2.3 - Access for each user type.

Section 2.4 - User authentication.

Database accuracy:

• PEMS and Tracker ASSC Section 2.6 - Separation of duties.

Section 3.0 - Audit trails.

• PEMS and Tracker Configuration Management Plans in SAMOA.

• PROC-ES-1002, Submitting, Reviewing, and Dispositioning Changes to the EIM Systems (OREIS, PEMS, and Tracker).

Analytical Services Table Worksheet 30 Provides validation criteria for non-standard or unpublished methodologies proposed for use for a

• • N/A.

Yes 1:8] No The program does not use non-standard given study. or unpublished methodologies for a given Worksheet 30 study.

Identifies individual(s) responsible for overseeing the success of the analysis and for implementing 1:8] Yes

• No

• Section 2.0, Project Organization, of the corrective actions if deemed necessary. WRRP QAPP identifies key project personnel.

Worksheet 30

• Section 17.0, Table 4 of the WRRP QAPP, identifies key roles responsible for overseeing and implementing corrective actions.

Specifies the turnaround time for hardcopy and electronic laboratory data deliverables.

1:8] Yes

• No

• The laboratory-specific SOW provides the Worksheet 30 required turnaround time for hardcopy and electronic data deliverables, a contractual requirement that is tracked in the TRACKER database. Standard turnaround time is 30 days unless otherwise noted.

Planned Project Assessment Table Worksheet 31 Lists the required number, frequency, and type of assessments with approximate dates and names of 1:8] Yes

• No

• Section 11.0, Assessments, of the WRRP QAPP addresses internal UCOR program Page 19 of 24

Element Meets Requirements individual(s) responsible for performing these assessments (i.e., Management Assessments),

assessments. subcontractor performance assessments (e.g.,

Worksheet 31 sampling subcontractor), and laboratory audits (i.e., DOE Consolidated Audit Program).

• The Fiscal Year Management Assessment schedule is currently being implemented and tracked in the Quality Assurance System (QAS).

• Quality Surveillance (conducted by QE) schedule is established and also tracked in QAS.

• Section 17.0, QA Reports to Management, of the WRRP QAPP, identifies the responsible individual(s) for performing assessments.

Discusses one or more of the following types of assessments: peer reviews, technical audits, 1:8] Yes

• No

• Section 11.0, Assessments, of the WRRP surveillance, management system reviews, QAPP, discusses several types of assessments readiness reviews, quality system audits, performed by UCOR, the subcontractor, or performance evaluations, data quality DOE.

assessments.

Worksheet 31 Assessment Findings and Corrective Action Responses Worksheet 32 Identifies the individual(s) performing these assessments and discusses the authority and 1:8] Yes

• No

• Section 11.0, Assessments, of the WRRP independence of these individual(s) in relation to QAPP, identifies and discusses assessment those being assessed. performers.

Worksheet 32 Provides a description of the types of corrective actions that may be instituted to resolve any 1:8] Yes

• No

• Section 14.0, Corrective Actions, of the WRRP issues identified during the audit. QAPP are managed in accordance with Worksheet 32 procedure PROC-PQ-1210, Issues Management Program.

Discusses where assessment findings will be documented and how the assessment findings will 1:8] Yes

• No

• Section 14.0, Corrective Actions, of the QAPP be communicated to all key project staff, state, instructs personnel how assessment findings and EPA personnel responsible for the study are managed in accordance with procedure oversight. PROC-PQ-1210, Issues Management Worksheet 32 Program, and how personnel are notified.

• Section 11.0, Assessments, of the WRRP QAPP, identifies and discusses assessment performers.

QA Management Report Table Page 20 of 24

Element Meets Requirements Identifies the frequency and distribution of the following types of reports:

Worksheet 33 Project Status Reports Worksheet 33 1:8] Yes

• No

• Section 17, QA Reports to Management, of the WRRP QAPP. Routine management assessments are conducted of sampling activities. As appropriate, an Issues/Corrective Action Status report is provided to project management.

Results of Assessments or Audits Worksheet 33 1:8] Yes

• No

• Assessment Reports are issued per requirements of procedure PROC-PQ-1210, Issues Management Program.

Results of periodic Data Quality Assessments Worksheet 33 1:8] Yes

• No

• Section 13.1, Project Data Quality Assessments, of the WRRP QAPP procedures for Precision, Accuracy, Representativeness, Completeness, and Comparability (PARCC) describes the process for the verification and validation for DQAs.

QA Audit Reports Worksheet 33 1:8] Yes

• No

• Section 11.0, Assessments, of the WRRP QAPP.

Identifies the individual(s) responsible for preparing, reviewing, and receiving these reports 1:8] Yes

• No

• Section 11.0, Assessments, and Table 4,

- discusses the retention time for maintaining such Routine Reports for the WRRP of the WRRP reports. QAPP includes the responsible person and Worksheet 33 frequency of assessment reports.

• Procedure PROC-PQ-1210, Issues Management Program.

• Procedure PROC-PQ-1420, Assessments.

Verification (Step I) Process Table Worksheet 34 Identifies the guidance documents or SOPs governing the data review, verification, and 1:8] Yes

• No

• SMO procedure PROC-ES-5002, Oak Ridge validation processes. Sample Management Office Laboratory Worksheet 34 Contract Compliance Verification and Invoicing.

• SMO procedures PROC-ES-5005, Oak Ridge Sample Management Office Laboratory Data Validation for Inorganic and Organic Analyses and PROC-ES-5006, Oak Ridge Sample Page 21 of 24

Element Meets Requirements Management Office Laboratory Data Validation for Radiochemical Analyses.

• Per National Functional Guidelines (EPA) for data review.

Validation (Steps IIa and IIb) Process Table Worksheet 35 Clearly discusses the criteria by which data will be accepted or rejected and provides a 1:8] Yes

• No

• SMO procedure PROC-ES-5002, Oak Ridge comprehensive list of the data flags or qualifiers Sample Management Office Laboratory that will be assigned to non-compliant data points Contract Compliance Verification and (including the definitions for each of these flags). Invoicing.

Worksheet 35

• SMO procedures PROC-ES-5005, Oak Ridge Sample Management Office Laboratory Data Validation for Inorganic and Organic Analyses and PROC-ES-5006, Oak Ridge Sample Management Office Laboratory Data Validation for Radiochemical Analyses discuss criteria for assignment of data flags and qualifiers, as well as provide definitions for each of the data flags.

Describes the process, and provides the criteria by which the data will be assessed for its overall 1:8] Yes

• No

• Section 13.0, Specific Routine Procedures, of usability and intended purpose. the WRRP QAPP procedures for Precision, Worksheet 35 - BD Accuracy, Representativeness, Completeness, and Comparability (PARCC) describes the process for the verification and validation for DQAs.

Validation (Steps IIa and IIb) Summary Table Worksheet 36 1:8] Yes

• No

• Section 9.3, Data Validation Approach, of the QAPP specifies the minimum requirements for data validation.

• SMO data validation procedures PROC-ES-5005, Oak Ridge Sample Management Office Laboratory Data Validation for Inorganic and Organic Analyses and PROC-ES-5006, Oak Ridge Sample Management Office Laboratory Data Validation for Radiochemical Analyses, provide the status of all validations that are scheduled and performed.

Usability Assessment Worksheet 37 Describes the process by which the on-site and off-site analytical data will be reconciled to the 1:8] Yes

• No

• Off-site and onsite analytical data may be project-specific requirements. reconciled to project-specific requirements per Worksheet 37 procedures PROC-ES-5002, Oak Ridge Sample Page 22 of 24

Element Meets Requirements Management Office Laboratory Contract Compliance Verification and Invoicing, PROC-ES-5005, Oak Ridge Sample Management Office Laboratory Data Validation for Inorganic and Organic Analyses and PROC-ES-5006, Oak Ridge Sample Management Office Laboratory Data Validation for Radiochemical Analyses.

Discusses how limitations in the final data set will be documented and communicated to all end data

~ Yes

• No

• Procedure PROC-ES-5002, Oak Ridge Sample users and stakeholders. Management Office Laboratory Contract Worksheet 37 Compliance Verification and Invoicing, requires issuance of the CCV report (containing any data limitations) to data end-users/stakeholders.

Describes the circumstances under which data would be rejected and removed from the final

~ Yes

• No

• Data validation procedures PROC-ES-5005, data set. Oak Ridge Sample Management Office Worksheet 37 Laboratory Data Validation for Inorganic and Organic Analyses and PROC-ES-5006, Oak Ridge Sample Management Office Laboratory Data Validation for Radiochemical Analyses lists the minimum items to be validated and a deficiency in one or more could result in the data being rejected. The validators professional judgment may be required. Some typical examples causing data rejection are:

Exceeded hold times, Out-of-calibration equipment, and Nonconformance of QC samples.

• Rejected data are not entered into the OREIS database (final data set); however, the data are archived in the PEMS database.

Identifies the individual(s) responsible for reconciling the data to the project-specific

~ Yes

• No

• Per PROC-ES-5002, Oak Ridge Sample requirements. Management Office Laboratory Contract Worksheet 37 Compliance Verification and Invoicing, the Analytical Data Coordinator (ADC) reconciles discrepancies.

Identifies the SOP or guidance document outlining the data usability process.

~ Yes

• No

• Section 13.0, Specific Routine Procedures, of Worksheet 37 the WRRP QAPP outlines the PARCC parameters.

Note: The EPA guidance and requirements documents for the DQO process, SAP preparation, Data Validation and Data Quality Assessments, are located at http://www.epa.gov/quality.

Page 23 of 24

Final SAP Disposition:

Approved, no comments Signature of Designated Approval Official (DAO)

Signature of Section Chief of the DAO Not Approved, Address Comments, Submit Revised SAP to the EPA Designated Approval Official Reference

1. Intergovernmental Data Quality Task Force Workbook for Uniform Federal Policy for Quality Assurance Project Plans Part 2A: UFP-SAP Workbook (EPA-505-B-04-900C) found at http://www.epa.gov/fedfac/documents/qualityassurance.htm.

Page 24 of 24

DOE/OR/01-2749&D1/A2/R2 RECORD COPY DISTRIBUTION FileDMCRC

UCOR an Amentum-led partnership with Jacobs Comment Resolution Form Document Number: Document

Title:

Addendum 2 to the Supplemental Sampling and Analysis Plan for the East Tennessee Technology Park DOE/OR/01-2749&D1/A2/R1 I Sitewide Residual Contamination Remedial Investigation K-31/K-33 Area, Oak Ridge, Tennessee Name of Reviewer: Craig Van Trees I Organization: EPA I Date Comments Transmitted: 06/14/21 Comment Sect./

Comment Response No. Page GENERAL

1. The RSE (Remedial Site Evaluation) remains an All references to the RSE have been removed with unapproved document per the approved IDRA and the exception of the discussion of the project should not be referenced in this RIWP/SAP. timeline. References for history of the area and the Additionally, new material pertaining to the RSE CSM have been revised to the Final Sitewide RI/FS has been presented in groundwater meetings with the tri- for the ETTP (DOE/OR-01-2279&D3).

parties (e.g., updated CSM, well data, etc.). Therefore, any updated material intended for the RSE should be Additional text addressing the CSM has been added to the SAP where appropriate and the Remedial added.

Investigation/Feasibility Study. Please remove all references to the unapproved RSE from the SAP, and update the document to include applicable RSE information, data, tables, and figures where appropriate.

However, it may be appropriate to reference the former RSE as background in the RI/FS.

2. It is unclear if completion of a risk assessment is A Baseline Human Health Risk Assessment warranted to aid in evaluation of a final groundwater (BHHRA) will be included in the K-31/K-33 decision for the site. If a risk assessment is warranted as RI/FS.

part of the remedial investigation/feasibility study, groundwater data should be screened against risk-based Table 5.1 has been revised to include RSLs rather screening levels (i.e., the Regional Screening Levels), than MCLs.

rather than the Maximum Contaminant Levels as currently proposed in Table 5.1 (Detailed analyte list, Reference to the BHHRA completed for the Final analytical methods, and reporting requirements for K- Sitewide RI/FS for ETTP has been added to 31/K-33 groundwater samples). Please clarify and Section 3.1.2: Chemicals of Concern.

update the related documentation appropriately.

Additionally, please reference the baseline risk assessment that identifies the risk associated with this project.

2749&D1 A2 R1 K-31_K-33 SAP Addendum comm EPA 061421 resp.docx Page 1 of 6

UCOR an Amentum-led partnership with Jacobs Comment Resolution Form Comment Sect./

Comment Response No. Page

3. In some instances, the DOEs responses in the Comment Clarifications and revisions specified in the Resolution Form (transmitted 3/30/21) have not Comment Resolution Form transmitted 3/30/21 consistently made their way into the revised RIWP/SAP. have been incorporated into the revised Please work with your document preparers to ensure all RIWP/SAP. See Specific Comment Responses clarifications and revisions are reflected in the next below.

revision of the RIWP/SAP. Some examples have been included in the specific comments section of this letter.

4. The SAP Addendum Title and Approval Page identifies The signature page has been revised to clearly the document title as Addendum 2 to the Supplemental indicate the signatories are signing the SAP Sampling and Analysis Plan for the East Tennessee Addendum only. The QAPP has already been Technology Park Sitewide Residual Contamination signed by all parties.

Remedial Investigation K-31/K-33 Area, Oak Ridge, Tennessee (DOE/OR/01 2749&D1/A2/R1) and

[emphasis added] the Quality Assurance Project Plan for the Water Resources Restoration Program, U.S.

Department of Energy, Oak Ridge Reservation, Oak Ridge, Tennessee, September 2019 (UCOR-4049/R6);

however, the first and third pages of the SAP Addendum identify the title of the document as Addendum 2 to the Supplemental Sampling and Analysis Plan for the East Tennessee Technology Park Sitewide Residual Contamination Remedial Investigation K-31/K-33 Area, Oak Ridge, Tennessee. Based on the SAP Addendum Title and Approval Page, it appears that the SAP Addendum is intended to be an addendum to both the Supplemental Sampling and Analysis Plan (Supplemental SAP) and the Quality Assurance Project Plan for the Water Resources Restoration Program (WRRP QAPP); however, since the Supplemental SAP and WRRP QAPP are separate documents, they should be updated separately (i.e., there should be a separate addendum to the WRRP QAPP). Revise the SAP Addendum Title and Approval Page to clarify that this 2749&D1 A2 R1 K-31_K-33 SAP Addendum comm EPA 061421 resp.docx Page 2 of 6

UCOR an Amentum-led partnership with Jacobs Comment Resolution Form Comment Sect./

Comment Response No. Page document is an addendum to the Supplemental SAP for the K-31/K-33 project only.

5. The Checklist indicates that key project personnel are There have been no changes to the key project identified in the WRRP QAPP, as well as project personnel, organizational structure, or information sampling standard operating procedures (SOPs) and included in the September 2019 version of the laboratory SOPs; however, the latest revision of the WRRP QAPP. The WRRP QAPP will be updated WRRP QAPP that is referenced is dated September in the near future; however, currently there is no 2019, and it is unclear if this information is still current specific date for the update to be completed. When (i.e., it is unclear if project personnel - or organizational the WRRP QAPP is updated, EPA will be structure - have changed since September 2019 or if any provided with the updated version for review and field or laboratory SOPs have been updated since approval, and new signatures.

September 2019). Therefore, it is unclear if the requirements for these elements have been met. Clarify whether project personnel, organizational structure, field SOPs, laboratory SOPs, or anything else listed in the 440-page document has changed since the latest approved revision of the WRRP QAPP. If any information in the WRRP QAPP (or any other referenced document) has changed since it was last revised, the updated information should be included in the SAP Addendum. Additionally, it would be helpful for the EPA to know when the next version of the WRRP QAPP is anticipated to be published.

SPECIFIC

1. Table 4.3, page 4-6 Update Laboratory Method for EPA-537 to state EPA- Laboratory Method has been updated to EPA-537.1. 537.1.

2. Synchronize with and reference the 2021 Remedial Chapter 2. SITE HISTORY, states that The K-31 Effectiveness Report (RER; DOE/OR/01-2869&D1). building demolition and slab removal were On Figure 7.48 of the RER, the K-31 slab is listed as a completed in 2015. The K-31 building slab was slab with provisional management. Please update the removed immediately following building RIWP/SAP Addendum to clarify whether the K-31 slab demolition and is not under provisional has been removed or remains under provisional management. The technical team for the RER has 2749&D1 A2 R1 K-31_K-33 SAP Addendum comm EPA 061421 resp.docx Page 3 of 6

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Comment Response No. Page management. Update the document to reflect this change received a similar comment and will fix the and reference the RER where appropriate. drawing in that report.

3. Evaluation of the Response to General Comment #1c The text in Section 4.1.1 has been revised to (3/30/21). It is unclear under what circumstances per- indicate that PFAS/PFOS results will be screened and polyfluoroalkyl (PFAS) data will be compared to the against the interim screening level of 40 ng/L to interim screening level of 40 nanograms per liter (ng/L) determine if further action is warranted.

versus the Health Advisory Limit of 70 ng/L. For example, the text in Section 4.1.1 (Quarterly Sampling) The RSL for perfluorobutane sulfonic acid (PFBS) states, If there are detections of PFAS/PFOS has been added to Table 5.1.

[perfluorooctane sulfonic acid] in groundwater in the K-31/K-33 Area in the second quarter sampling results that are greater than EPA action levels, additional PFAS/PFOS sampling will be conducted. It is unclear if the action level referenced is the interim screening level or the Health Advisory Limit. Similarly, Table 5.1 (Detailed analyte list, analytical methods, and reporting requirements for K-31/K-33 groundwater samples) references the Health Advisory Limit, but not the interim screening level, and it is unclear why this is the case.

Finally, it is noted that a Regional Screening Level for perfluorobutane sulfonic acid (PFBS) is available, but this is not listed in Table 5.1. Clarify in the revision of the SAP Addendum under what circumstances data will be compared to the interim screening level versus the Health Advisory Limit. In addition, include the Regional Screening Level for PFBS in Table 5.1, consistent with the response, or state why this was not done.

4. Evaluation of the Response to General Comment #4 Additional text has been added to explain that (3/30/21). The SAP Addendum has not been revised to VOCs will be analyzed in samples collected from explain why volatile organic compound (VOC) sampling the K-31/K-33 monitoring wells with historical is warranted at only a limited number of existing wells detections of VOCs. Text on the potential source and the new piezometers. In addition, the SAP of VOCs in the K-31/K-33 Area has been added to Addendum does not include the piezometers and the Chapter 3.

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Comment Response No. Page associated analytical suite in Table 4.1 (K-31/K-33 Area groundwater sampling results summary and wells The new piezometers and analytical suite have proposed for further sampling). Revise the SAP been added to Table 4.1.

Addendum to explain why VOC sampling is warranted at a limited number of wells only, including a discussion of possible sources of VOC contamination. In addition, ensure Table 4.1 is revised to include the piezometers and associated analytical suite.

5. Evaluation of the Response to Specific Comment #2 Laboratory sample hold times and reporting limits (3/30/21). Regarding PFAS, the response does not state for PFAS are included in Table 5.1. Other if the information requested in the comment laboratory quality assurances such proficiency (i.e., laboratory quality assurances such as sample hold testing, and accreditation information are reviewed time/preservation studies, proficiency testing, and routinely by the DOE Sample Management Office.

accreditation information) will be obtained and Documentation can be provided to the regulatory reviewed, and if such documentation will be provided to agencies if requested.

the regulatory agencies. Clarify if and how the issue identified in Specific Comment #2 will be addressed.

6. Evaluation of the Response to Specific Comment #3 The text in Section 4.1.1 has been revised to (3/30/21). Section 4.1.1 (Quarterly Sampling) still states, indicate that the 18 PFAS/PFOS chemicals The PFAS/PFOS chemicals to be reported include the addressed in EPA Method 537.1 will be analyzed Navy 14 parameters as described in the Navys Interim and reported.

Guidance. Revise the quoted statement to clarify that samples will be analyzed for 18 PFAS and ensure consistency throughout the document.

7. Evaluation of the Response to Specific Comment #4 The text in Table 4.1 has been revised to indicate (3/30/21). The text in Section 4.1.1 (Quarterly Sampling) that if EPA screening levels for PFAS/PFOS are states, If there are detections of PFAS/PFOS in exceeded in the results for the second quarter groundwater in the K-31/K-33 Area in the second sampling event, additional PFAS/PFOS samples quarter sampling results that are greater than EPA action will be collected in the third quarter sampling levels, additional PFAS/PFOS sampling will be event, to be consistent with the text in Section conducted during the third quarter sampling event. In 4.1.1.

addition, Table 4.1 (K-31/K-33 Area groundwater sampling results summary and wells proposed for further 2749&D1 A2 R1 K-31_K-33 SAP Addendum comm EPA 061421 resp.docx Page 5 of 6

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Comment Response No. Page sampling) only states that samples will be analyzed for PFAS in the third quarter; it does not state that analysis for PFAS will be conducted in the second quarter.

Revise Section 4.1.1 and Table 4.1 for consistency with the response.

8. Evaluation of the Response to Specific Comment #11 There is confusion in comparing the project action (3/30/21). The response partially addresses the comment. limits (PALs) to the laboratory reporting limit Two issues were identified in review of Table 5.1 (RLs) indicated in Table 5.1 because of the (Detailed analyte list, analytical methods, and reporting different units used in the table. The PALs for requirements for K-31/K-33 groundwater samples): compounds listed in the comment are in mg/L versus the RLs, which are in µg/L. With the A. Numerous instances (e.g., see 1,1-dichloro-ethene, inclusion of the RSLs instead of MCLs in Table benzene, carbon tetrachloride, trichloroethene, 5.1 as requested in General Comment #2, there are etc.) were identified in which the project action some chemicals with PALs greater than the RLs.

limit (PAL) is less than the laboratory reporting However, in most cases these chemicals also have limit (RL); however, the uncertainty associated an MCL, which is greater than the laboratory RL.

with using such data is not discussed. The SAP Text has been added to indicate that screening Addendum should discuss the uncertainty against MCLs will be performed if the PAL is less associated with results in which the PALs are less than the RL, and the BHHRA to be prepared will than the RLs, and address (where applicable) why follow the EPA risk assessment process.

the data will be sufficient to meet project data quality objectives.

B. A PAL is not provided for numerous analytes. It PALs have been added for all chemicals that have is unclear how data for these analytes will be an EPA RSL. All chemicals will be assessed in assessed. accordance with the EPA risk assessment process in the BHHRA.

9. General Revise the SAP Addendum to provide a detailed Text has been added to explain that chemicals will discussion of uncertainty in cases where the PAL is less also be screened using the MCL, and the BHHRA than the RL, and address if data will be of sufficient will determine the chemicals of concern in quality to meet project data quality objectives. In accordance with the EPA risk assessment process.

addition, explain how data for analytes with no PALs will be evaluated.

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