PFM-00164

i January 2020 Trademarks and registered trademarks are property of their respective owners.

MISSION SUPPORT CONTRACT

REGULATORY DECISION DOCUMENT (RDD) DATABASE MAINTENANCE AND

REPORTING DESK INSTRUCTION

Regulatory Decision Document Database Desk Instruction

PFM-00164

iii January 2020

CHANGE HISTORY

Version Date Change Author Change Summary 0 August 8, 2019 K.R. Moser Updated existing DOE RDD RIMS procedure to

incorporate current practice for release as a desk instruction.

1 January 9, 2020 K.R. Moser RDD bug fix in December 2019 now allows directly copying the RDD URL from the Administrative Record into the Regulatory Documents Control Table.

Regulatory Decision Document Database Desk Instruction

PFM-00164

iv January 2020

CONTENTS

1.0 PURPOSE ..........................................................................................................................1

1.1 ROLES AND RESPONSIBILITIES ...................................................................3 1.1.1 DOE-RL RDD Project Manager .............................................................3 1.1.2 DOE-RL RDD Groundwater Liaison .....................................................3 1.1.3 PFM RDD Project Manager ....................................................................3 1.1.4 PFM Project Team Members ..................................................................3

2.0 RDD DATABASE MAINTENANCE PROCESS ............................................................3

2.1 IDENTIFY RDDS ...............................................................................................4 2.2 IDENTIFY RDD ENVIRONMENTAL CLEANUP OBJECTS AND

REMEDIES .........................................................................................................5 2.3 ENTER RDD INFORMATION ON RDD CONTROL TABLE ........................5 2.4 ENTER RDD INFORMATION ON INPUT TABLES ......................................9 2.5 VERIFICATION ...............................................................................................14

3.0 SUGGESTED GUIDELINES .........................................................................................15

FIGURES

Figure 1. RDD Database Generalized Maintenance Process. ........................................................ 3

Figure 2. Relationship of Selected RDDs in the CERCLA Response Action Process. ................. 6

APPENDICES

A. DEFINITIONS: REGULATORY DECISION DOCUMENTS ........................................17

Regulatory Decision Document Database Desk Instruction

PFM-00164

1 January 2020

1.0 PURPOSE

This desk instruction describes the process for updating and maintaining the Regulatory Decision Document (RDD) database. The RDD database provides a central location for Hanford staff to easily locate applicable RDDs by Operable Unit and individual environmental cleanup objects (e.g., waste site, facility, pipeline, or groundwater). Initial RDD database development in 2014 resulted in on-screen reports (with hyperlinks) that can be exported to Excel®. The Regulatory Decision Documents Reports link under Project Documentation at the Project Data Management System (PDMS) SharePoint site (https://hanfordsite.sharepoint.com/sites/doe-amms/pdms/SitePages/Home.aspx) displays the following RDD Home Page, which can be used to access and export the various on-screen reports.

Subsequent RDD development in 2015 and 2018 incorporated the ability to geographically display, query and filter environmental cleanup objects and their attributes along with Hanford Site map layers to support cleanup work planning by DOE and contractor personnel for the Project Baseline Summary (PBS) RL-40 Nuclear Facility Decontamination and Decommissioning (D&D) – Remainder of Hanford Project. The Cleanup Planning Map application can be accessed from the Hanford Geographic Information System (HGIS) website (http://hgis.rl.gov/hgis/). It replaced the GeoVis application in 2018. The Cleanup Planning Map application has several unique data layers, including RDD status for facilities and waste sites (shown below), Baseline Cleanup Remedy, RDD Remedy, Waste

Regulatory Decision Document Database Desk Instruction

PFM-00164

2 January 2020

Information Data System (WIDS) waste sites by Operable Unit and Facility Overall Asset Condition. The application also includes more query fields including the ability to filter results using Implementation Areas, Subsequent Units for Individual Development (SqUID) or Operable Units, and it contains several custom built-in queries (i.e., workflows) under the “I want to…” tab to facilitate user-specified queries.

Initially, the RDD database focused on incorporating the waste site decision documents within the Hanford Site Central Plateau area, but it was expanded between 2016 and 2019 to include regulatory decision documents for waste sites, facilities and groundwater Operable Units across the Hanford Site. The RDD database, on-screen reporting tool and Cleanup Planning Map application will serve as tools to validate the Central Plateau and remaining River Corridor baseline remediation/disposition planning utilizing a geographic area approach. Appendix A provides definitions of the RDD terms used in this desk instruction.

Regulatory Decision Document Database Desk Instruction

PFM-00164

3 January 2020

1.1 ROLES AND RESPONSIBILITIES

1.1.1 DOE-RL RDD Project Manager The U.S. Department of Energy (DOE), Richland Operations Office (RL) RDD Project Manager is the DOE representative responsible for defining the purpose and requirements of the RDD database and associated tools. This representative is also responsible for identifying the documents to be included in the RDD database. The PBS RL-40 Project Control Officer serves as the DOE-RL RDD Project Manager.

1.1.2 DOE-RL RDD Groundwater Liaison RDD groundwater documents to be included in the RDD database are identified on an ad hoc basis by the PBS RL-30 Director or designee.

1.1.3 PFM RDD Project Manager The PFM RDD Project Manager is appointed by the PFM Director to lead the maintenance of the RDD database and interface with the RL RDD Project Manager and Groundwater Liaison.

1.1.4 PFM Project Team Members The PFM project team members are responsible for the timeliness and quality of a specifically defined maintenance activity, RDD database update, etc., within the bounds of their authority as defined by the PFM Director.

2.0 RDD DATABASE MAINTENANCE PROCESS

The generalized RDD database maintenance process is summarized in Figure 1. Details of each step are described in the subsequent sections.

Figure 1. RDD Database Generalized Maintenance Process.

1•Identify RDDs

2•Identify RDD environmental cleanup objects & remedies

3•Enter RDD Information on Control Table

4•Enter RDD Information on Input Tables

5•Verification

Regulatory Decision Document Database Desk Instruction

PFM-00164

4 January 2020

2.1 IDENTIFY RDDS Data is entered into the RDD database on an as needed basis after new RDDs have been released or existing RDDs are identified for inclusion. Generally, the DOE-RL RDD Project Manager or Groundwater Liaison send an email to the PFM RDD Project Manager requesting the document(s) to be included in the RDD database after they have been released to the TPA Administrative Record (AR). Infrequently, draft documents that are only available in the Integrated Data Management System (IDMS) are requested to be included. The following types of decision documents can be entered into the RDD database for waste sites, pipelines and facilities (see Appendix A for definitions):

• Interim Action Documents o Engineering Evaluation/Cost Analysis (EE/CA) o Action Memorandum (AM)

• Resource Conservation and Recovery Act of 1976/Comprehensive Environmental Response, Compensation and Liability Act of 1980 (RCRA/CERCLA) Corrective Action Documents

o Work Plan o Remedial Investigation (RI)/RCRA Facility Investigation (RFI) o Feasibility Study (FS)/Corrective Measures Study (CMS) o Proposed Plan (PP)/Proposed Corrective Action Decision o Record of Decision (ROD)/Corrective Action Decision (CAD)

• RCRA Documents o National Environmental Policy Act of 1969 (NEPA) Review/Documentation o Closure Plan/Post-Closure Plan o State Environmental Policy Act (SEPA) Documentation o Permit Modification

• Implementing Documents o Remedial Design/Remedial Action Work Plan (RD/RAWP) o Corrective Action Work Plan (CAWP) o Removal Action Work Plan (RAWP)

• Other Documents o TPA Change Notices that implement changes to these RDDs o Revisions to these RDDs (including AM Amendment, ROD Amendment and

ROD Explanation of Significant Differences [ESD]).

For groundwater RDDs, the Groundwater Liaison may request that the interim action documents, CERCLA documents, implementing documents and other documents listed above be included in the RDD database. In addition, the following groundwater RDDs may also be included in the RDD database (see Appendix A for definitions):

• Other Documents

Regulatory Decision Document Database Desk Instruction

PFM-00164

5 January 2020

o Sampling and Analysis Plan (SAP) o Performance Monitoring Plan (PMP) o Operations and Maintenance Plan (OMP) o Treatability Test Plan (TTP) o Waste Control Plan/Waste Management Plan (WCP/WMP).

The order and relationship of many of the RDDs in the CERCLA response action process are provided in Figure 2 (see red underline).

2.2 IDENTIFY RDD ENVIRONMENTAL CLEANUP OBJECTS AND REMEDIES Unless otherwise noted, the remaining RDD database maintenance steps in this desk instruction are performed by the PFM RDD Project Manager or their designee. Step 1 - Open the TPA Administrative Record (AR) (https://pdw.hanford.gov/arpir/) to locate and open the RDD document file. The most useful predefined searches for locating RDDs in the AR are:

• By Document Type • By Operable Unit • By Added Within Last 90 Days, or • Open “Use Advanced Search”, open the dropdown box in Criteria, select Document

Number, then enter the Document Number in the dialog box and click on “Search”.

For draft documents that are only available in IDMS (http://idmsweb.rl.gov/idms/livelink.exe?func=llworkspace), the DOE-RL RDD Project Manager or Groundwater Liaison must provide a link to the document location in IDMS. Step 2 - After opening the RDD document link in the AR or IDMS, carefully review the RDD to identify the environmental cleanup objects (e.g., waste site, facility, pipeline or groundwater) within the scope of the RDD. The list of objects may be provided in the text, tables, figures or appendices. Also, carefully review the RDD to identify the cleanup remedy for each environmental cleanup object. Proposed and selected cleanup remedies are only found in a subset of the RDDs (proposed in the EE/CA, FS, CMS, PP or Proposed CAD, selected in the AM, ROD, CAD or Closure Plan and implemented by the RAWP, RD/RAWP or CAWP). TPA Change Notices may also implement minor changes to the cleanup remedies. Tables or document sections may address different cleanup remedies for groups of cleanup objects. Step 3 - For future use and verification, print the RDD coversheet and the pages that identify the RDD environmental cleanup objects and their cleanup remedies.

2.3 ENTER RDD INFORMATION ON RDD CONTROL TABLE The RDD database uses a SharePoint site (https://hanfordsite.sharepoint.com/sites/msa-pm/sitepages/regulatory%20decision%20document%20linkage%20development.aspx) for

Regulatory Decision Document Database Desk Instruction

PFM-00164

6 January 2020

document entry, updating and maintenance. For access permission, contact the RDD SharePoint site administrator via email.

Figure 2. Relationship of Selected RDDs in the CERCLA Response Action Process. Step 1 - Open the RDD SharePoint site and from the home page select the “Regulatory Documents Control Table” link as shown below.

(FS)

Regulatory Decision Document Database Desk Instruction

PFM-00164

7 January 2020

Prior to entering an existing RDD (e.g., one that has been released in the past) into the control table, check to verify that the existing RDD has not already been entered into the table. Select “Quick edit” then use the column headers of “Doc Type” or “Document #” to filter the table and perform this check. Because the RDD database was designed to associate an RDD with only one environmental cleanup object type (waste site, pipeline, facility or groundwater), RDD documents that cover both waste sites and groundwater (e.g., RODs) must have separate entries – these are not duplicate entries. If the RDD has not been entered, then proceed to Step 2. If it has already been entered, then stop and inform the DOE-RL RDD Project Manager or Groundwater Liaison. Step 2 - After opening the Regulatory Documents Control Table and selecting “Quick edit”, select the “Doc ID #” column header as shown below and select “Sort Descending” to identify the last Doc ID # entered. Then scroll to the open row at the bottom of the table and enter the next sequential number under the “Doc ID #” column. The Doc ID # is used to associate the RDD with environmental cleanup objects on the “Waste Sites”, “Facilities” or “GW Waste Sites” SharePoint input tables. Note that all RDDs entered in the control table are retained but only the latest version for each document type is displayed in the RDD reports.

Regulatory Decision Document Database Desk Instruction

PFM-00164

8 January 2020

Step 3 - After entering the next sequential Doc ID # in the open row, enter the following information for the RDD. Note that it is useful to have the RDD document open from the AR or IDMS on one screen so that information can easily be copied into the control table.

• Doc Type – Use the dropdown arrow in this cell to open the list of available RDD document types, then select the appropriate document type.

• Document # - Copy or enter the document number from the AR or IDMS document file. Note that some RDDs (e.g., ROD) typically do not have document numbers, if so, leave this cell blank.

• Revision # - Enter the document revision number from the AR or IDMS document file. If the RDD has no revision number, leave this cell blank.

• Long Doc Title - Copy or enter the long (e.g., complete) document title from the AR or IDMS document file.

• Short Doc Title – Enter a short (abbreviated) document title by following the Short Doc Title abbreviations developed for similar RDDs.

• Fac Group – The Fac (Facility) Group column only applies to RDDs associated with facility environmental cleanup objects. For RDDs associated with other environmental cleanup objects (e.g., waste site, pipeline or groundwater) use the dropdown arrow in this cell to select “Not applicable”. For the facility RDDs, use the dropdown arrow in this cell to select either Gen Decon (e.g., general decommissioning), Tier 1, Tier 2, or Tier 1 and Tier 2. The facility RDD document title may indicate which facility group applies. If not, use the table in Appendix J – Central Plateau Facilities and 100 Area Production Reactors, which is in the Action Plan of the Tri-Party Agreement (see https://www.hanford.gov/files.cfm/ap-APP-J.pdf). The facilities determined to be Tier 1 or Tier 2 are listed in the Appendix J table. Some RDDs address facilities across multiple facility groups. For example, the Removal Action Work Plan for the Reduction-Oxidation

Regulatory Decision Document Database Desk Instruction

PFM-00164

9 January 2020

Complex (DOE/RL-2017-06, Rev. 0) addresses the 202S Canyon (Tier 1), 276S facility (Tier TBD [to be determined]) and 293S building (Tier TBD). The facility with the lowest tier number (the greater hazard) is used to select the Fac Group, so for this example Tier 1 is selected for this RDD.

• Accession # - Copy or enter the accession number from the AR or IDMS document file. • URL - Copy the URL from the AR or IDMS document file. • Status - Use the dropdown arrow in this cell to open the list of choices and select either

Approved or Draft. Note that approved RDDs are usually Revision 0 or greater or are those that are signed by the TPA agencies.

• Published Doc Date - Enter the RDD publication date in m/d/yyyy format or select the date using the calendar on the left side of the cell. The publication date is typically the date of the public release approval on the coversheet of the RDD or the “Document Date” shown in the AR Record Details page that can be accessed by clicking on the document record link in the AR search results page.

• Cleanup Object Type - Use the dropdown arrow in this cell to open the list of choices and select either waste site, facility, pipeline or groundwater, based on the main focus of the RDD.

Step 4 - After completing entry of the RDD information, verify that all of the information has been entered or copied correctly from the AR or IDMS document file, then click on the “Exit quick edit” tab at the top of the page, and after exiting, click on the back arrow at the top left of the screen to return to the RDD SharePoint site homepage.

2.4 ENTER RDD INFORMATION ON INPUT TABLES The “Doc ID #” (assigned to the RDD in the previous section) is used to associate the RDD with individual environmental cleanup objects (e.g., waste site, facility, pipeline, or groundwater) on one of three SharePoint input tables, either “Waste Sites”, “Facilities” or “GW Waste Sites,” as shown below. The process is similar for both the “Waste Sites” and “Facilities” SharePoint input tables (except that facilities are not grouped into operable units), so they are described together. The process for “GW Waste Sites” is different and it is described separately.

Regulatory Decision Document Database Desk Instruction

PFM-00164

10 January 2020

Step 1 - For waste sites or pipelines, open the “Waste Sites” SharePoint input table, and for facilities open the “Facilities” SharePoint input table. These two input tables have similar layouts as shown below. The first column is the Waste Site Code (or Facility ID). The second column in the “Waste Sites” table is RDD Operable Unit (this column is not in the “Facilities” table because facilities are not grouped into operable units). The remaining columns in both tables list the various RDD document types, followed by a Remedy column. Click “Quick edit” at the top of the table. Waste Sites Input Table Facilities Input Table

Step 2 - Using the RDD printout from Section 2.2 Step 3 that identifies the RDD environmental cleanup objects and their cleanup remedies, search the appropriate input table for the corresponding “Waste Site Code” or “Facility ID” for each cleanup object in the printout. There are several ways to search these tables, either by scrolling down a page and moving to following pages from the bottom of a page, or by entering the waste site code or facility ID in the “Search”

Regulatory Decision Document Database Desk Instruction

PFM-00164

11 January 2020

box in the upper left of the input table. If a match is found, click on “See more results” and if the appropriate RDD document type column is blank, then enter the “Doc ID #” to associate the RDD with that individual waste site, pipeline or facility. Step 3 - If a match is found and the appropriate RDD document type column already contains another “Doc ID #”, then use the “Regulatory Documents Control Table” to compare the “Published Doc Date” of the two “Doc ID #s”. The most recent “Published Doc Date” is used to decide which RDD should be associated with a waste site, pipeline or facility. If the “Published Doc Date” of the RDD being entered is more recent than the “Published Doc Date” of an RDD already associated with a waste site, pipeline or facility in the input table (for the same document type), then replace the “Doc ID #” in the appropriate RDD document type column, and if it is not more recent, then do not replace it. That way the input tables will always reflect the most current regulatory decision documents for each document type and waste site, pipeline or facility. Step 4 - If no match exists within the input table, then scroll to a new row at the bottom of the appropriate input table page and enter the “Waste Site Code” or “Facility ID” for the waste site, pipeline or facility and then enter the “Doc ID #” in the appropriate RDD document type column to associate the RDD with that individual waste site, pipeline or facility. Step 5 - Note that for the RDD Gap Reports to function correctly the waste site code must match the format in the Waste Information Data System (WIDS) and the Facility ID must match the format in the Hanford Site Structure List (facility names typically do not have hyphens). The format can be checked for waste sites and pipelines by opening the most recent annual revision of the Hanford Site Waste Management Units Report (DOE/RL-88-30, Revision 28 published February 2019 is at https://pdw.hanford.gov/arpir/pdf.cfm?accession=AR-01087 in the AR), then enter the keystrokes Control + F to open Find, then enter the waste site code in the dialog box. If a match is found, the format is correct, but if no match is found, the format/capitalization may need editing as this report lists all WIDS sites. The format for facilities can be checked against the Structure ID in the Hanford Site Structure List (the most current HSSL link in Excel is at http://msc.ms.rl.gov/rapidweb/Facility/index.cfm?PageNum=20). Scroll through the HSSL file or use Excel’s Find function to enter the facility ID in the dialog box. If a match is found, the format is correct, but if no match is found, the format/capitalization may need editing. Step 6 - Proposed and selected cleanup remedies are only found in a subset of the RDDs (proposed in the EE/CA, FS, CMS, PP or Proposed CAD, selected in the AM, ROD, CAD or Closure Plan and implemented by the RAWP, RD/RAWP or CAWP). TPA Change Notices and other document changes may also implement changes to the cleanup remedies. RDD tables or document sections may address different cleanup remedies for groups of cleanup objects. For the RDDs that identify the cleanup remedies for waste sites, pipelines or facilities, scroll to the “Remedy” column on the right of the appropriate input table and select the appropriate cleanup remedy from the drop down list. Use the “Remedy Crosswalk” table on the bottom of the RDD SharePoint home page (shown below) to identify the correct “Regulatory Remedy Short” name to be used in the input tables. Note that during the removal or remedial action process (Figure 2) the cleanup remedy may change, so if the input table already has a remedy for a waste site, pipeline or facility, use the following RDD document hierarchy to determine if the remedy entry should be changed. Cleanup remedies in proposed RDDs (listed above) are superseded by selection RDDs, which are superseded by implementation RDDs, which may be superseded by

Regulatory Decision Document Database Desk Instruction

PFM-00164

12 January 2020

RDD document changes (TPA Change Notice, AM Amendment, ROD Amendment or ROD ESD).

Step 7 - For RDDs that address waste sites or pipelines, select the appropriate RDD Operable Unit from the drop down list in the “RDD Operable Unit” column. The RDD Operable Unit for waste sites or pipelines is usually identified in the RDD. If the RDD Operable Unit is not identified in the RDD, the most current assignment of waste sites and pipelines to Operable Units can be found by opening the most recent annual revision of the Hanford Site Waste Management Units Report (DOE/RL-88-30, Revision 28 published February 2019 is at https://pdw.hanford.gov/arpir/pdf.cfm?accession=AR-01087 in the AR), enter the keystrokes Control + F to open Find, then enter the waste site code in the dialog box. After the waste site or pipeline entry is located, scroll forward or backward in the document to find the Operable Unit section header, or use the document Table of Contents to associate the page number of the entry with the correct Operable Unit. Then enter this Operable Unit from the drop down list in the “RDD Operable Unit” column. This method is valid for RDDs published after about 2010, because although waste sites and pipelines have been assigned to different Operable Units over the years, the last major realignment was in 2010. Step 8 - Repeat Steps 2-7, as appropriate, until all waste sites, pipelines or facilities (and their cleanup remedies) in the RDD have been entered on the appropriate RDD input table. Then click on the “Exit quick edit” tab at the top of the page, and after exiting, click on the back arrow at the top left of the screen to return to the RDD SharePoint site homepage.

For Groundwater RDDs Step G1 - For groundwater RDDs, open the “GW Waste Sites” SharePoint input table from the RDD SharePoint home page, then click on “Quick edit” at the top of the page to display the input table shown below. Step G2 - Groundwater RDDs are only associated with groundwater Operable Units and RDD document types, so the input table has only three columns: “GW OU”, “Doc Type”, and “Doc

Regulatory Decision Document Database Desk Instruction

PFM-00164

13 January 2020

ID”. Using the RDD printout from Section 2.2 Step 3 to identify the groundwater RDD document type and groundwater Operable Unit(s), filter the “GW OU” or “Doc Type” columns that match those in the RDD printout, then review the table and identify any “Doc IDs” that match the GW OU and document type in the printout. Then open the “Regulatory Documents Control Table” from the RDD SharePoint home page and review the RDD information for the Doc ID matches. The purpose of this review is to identify the most current RDD for each document type and groundwater Operable Unit so that the GW Waste Sites input table will always reflect the most current regulatory decision document type for each groundwater Operable Unit. However, for groundwater Operable Units it is possible and acceptable to have more than one RDD document type. For example, the RDD database includes 11 SAPs for the 100-KR-4 groundwater Operable Unit that each address different parts of the Operable Unit plus approved changes.

Step G3 - If the review of the RDD information for the Doc ID matches indicates that the groundwater RDD is unique (e.g., it is not already covered by existing entries for the same RDD document type), then scroll to a new row at the bottom of the input table page, select the appropriate groundwater Operable Unit from the dropdown list in the “GW OU” column, then select the appropriate groundwater RDD document type from the dropdown list in the “Doc Type” column and enter the Doc ID # in the “Doc ID” column. Note that if the groundwater RDD covers multiple groundwater Operable Units, a separate entry must be made to select each groundwater Operable Unit from the dropdown list in the “GW OU” column (as shown by the green arrows in the image above).

Regulatory Decision Document Database Desk Instruction

PFM-00164

14 January 2020

Step G4 - If the review of the RDD information for the Doc ID matches indicates that the groundwater RDD is already covered by existing entries for the same RDD document type, then use the “Regulatory Documents Control Table” to compare the “Published Doc Date” of the two “Doc ID #s”. The most recent “Published Doc Date” is used to decide which RDD should be associated with a groundwater Operable Unit and RDD document type. If the “Published Doc Date” of the RDD being entered is more recent than the “Published Doc Date” of an RDD already associated with the same groundwater Operable Unit and RDD document type (considering the exception described above), then replace the Doc ID # in the “Doc ID” column, and if it is not more recent, then do not replace it. That way the input table will always reflect the most current regulatory decision documents for each groundwater Operable Unit and RDD document type. Step G5 - Contact the Groundwater Liaison for resolution of any issues with groundwater RDDs that are not covered by this desk instruction.

2.5 VERIFICATION The Regulatory Decision Documents Reports under Project Documentation at the PDMS SharePoint site (https://hanfordsite.sharepoint.com/sites/doe-amms/pdms/SitePages/Home.aspx) updates information from the RDD database every 15 minutes so that any changes are quickly available in the reports. This feature can be used to verify that the RDD database maintenance process described in the previous sections has been correctly implemented. Step 1 - Allowing at least 15 minutes after making any changes to the RDD database tables, open the Regulatory Decision Documents Reports home page at the PDMS site link provided above. Step 2 - Open the appropriate reports to verify that the changes are included and are correctly displayed. For waste site or pipeline RDD changes, first open the RDD OU Summary Status Report to show the status of RDDs for waste sites and pipelines, by Operable Unit. After opening the report, click on the “Export to Excel” button at the top right of the page, which will open the report in Excel. Within the Excel file, click the “Enable Editing” button at the top of the page, then use the column filter buttons to filter on the appropriate Operable Unit and RDD document type to view the RDD change(s). If the change is correctly displayed, then open the Waste Sites Detail Report from the RDD Report home page. This report lists all waste sites and pipelines in alphanumeric order that are covered by an RDD, displaying each applicable RDD, Operable Unit, their status within the CERCLA/RCRA process, and their remedy. After opening the report, follow the steps above to open the report in Excel, then use the column filter buttons to filter on the appropriate RDD document type to view the RDD change. Then compare the waste site code entries in the Excel file to the RDD printout from Section 2.2 Step 3 to verify that all waste sites and pipelines covered by the RDD are correctly shown and that the Remedy column in the Excel file displays the correct cleanup remedy for each waste site or pipeline. Step 3 - If all of the waste site or pipeline RDD changes are correctly displayed in these two reports the verification step is complete. If any errors are discovered, open the Regulatory Documents Control Table and/or the Waste Sites table from the RDD SharePoint site and correct the appropriate RDD entry. When the verification step is complete, notify the DOE-RL RDD

Regulatory Decision Document Database Desk Instruction

PFM-00164

15 January 2020

Project Manager that the requested RDD(s) has been incorporated into the RDD database. Contact the RDD SharePoint administrator for any issues that cannot be resolved by this desk instruction. Step 4 - For facility RDD changes, first open the RDD Facilities Summary Status Report to show the status of RDDs for facilities, by Facility Group. Follow the steps described above to open the report in Excel and filter on the RDD document type to view the RDD change(s). If the change is correctly displayed, then open the Facilities Detail Report. This report lists facilities in alphanumeric order that are covered by an RDD, displaying each applicable RDD, facility type, their status within the CERCLA/RCRA process, and their remedy. After opening the report, follow the steps above to open the report in Excel, filter on the appropriate RDD document type to view the RDD change(s) and compare the facility ID entries and remedies in the Excel file to the RDD printout from Section 2.2 Step 3. Step 5 - If all of the facility RDD changes are correctly displayed in these two reports the verification step is complete. If any errors are discovered, open the Regulatory Documents Control Table and/or the Facilities table from the RDD SharePoint site and correct the appropriate RDD entry. When the verification step is complete, notify the DOE-RL RDD Project Manager that the requested RDD(s) has been incorporated into the RDD database. Contact the RDD SharePoint administrator for any issues that cannot be resolved by this desk instruction. Step 6 - For groundwater RDD changes, open the RDD Groundwater OU Summary Status Report. This report shows the status of groundwater RDDs by groundwater Operable Unit. Follow the steps described above to open the report in Excel and filter on the groundwater Operable Unit and RDD document type to view the RDD change(s) and compare the entries to the RDD printout from Section 2.2 Step 3. Step 7 - If all of the groundwater RDD changes are correctly displayed in this report the verification step is complete. If any errors are discovered, open the Regulatory Documents Control Table and/or the GW Waste Sites table from the RDD SharePoint site and correct the appropriate RDD entry. When the verification step is complete, notify the Groundwater Liaison that the requested RDD(s) has been incorporated into the RDD database. Contact the RDD SharePoint administrator for any issues that cannot be resolved by this desk instruction.

3.0 SUGGESTED GUIDELINES

Although the RDD database maintenance process described in Section 2.0 covers the majority of RDD database issues that have typically been encountered since the initial development in 2014, several of the more unique issues that have not been previously addressed by this desk instruction and suggestions for handling them are described below. Contact the DOE-RL RDD Project Manager or Groundwater Liaison for resolution of any issues that cannot be resolved by this desk instruction.

1. The RDD printouts of the RDD coversheet and the pages that identify the RDD environmental cleanup objects and their cleanup remedies produced in Section 2.2 Step 3 are useful for checking previous RDD entries and for comparing the Published Doc Date of RDDs when there are existing entries in the Waste Sites, Facilities or GW Waste Sites

Regulatory Decision Document Database Desk Instruction

PFM-00164

16 January 2020

input tables. Write the Doc ID # and AR accession number on each RDD printout and retain them for future reference. However, note that these RDD printouts are not records as they are working copies of portions of documents in the AR or IDMS.

2. Some documents (e.g., RDR/RAWP for the 100 Area, DOE/RL-96-17, Rev. 6) identify waste sites but not Operable Units. In this case, Operable Units were assigned to waste sites using the latest version of the Hanford Site Waste Management Units Report (DOE/RL-88-30, Rev. 28, February 2019) – this PDF file is easy to search for specific waste sites. Because DOE/RL-96-17 did not identify the remedy for all waste sites and the cleanup work was completed when the RDD was entered in the database, the DOE/RL-88-30 document was also used to identify the waste site remedy.

3. Some documents (e.g., DOE/RL-88-30 and ROD for 100-DR-1, DR-2, HR-1, HR-2 and HR-3 OUs, July 2018) provide remedies for sub-sites of waste sites, and many times they may be different remedies. The RDD database does not include sub-sites of waste sites, so the most extensive remedy was typically assigned to the waste site. For example, if a waste site had 3 sub-sites with remedies of No action, CS/NFA and RTD, the RTD remedy was assigned to the overall waste site.

4. Typically published document dates are used to decide which document information to enter into the RDD input tables in cases where there are more than one RDD document type for a waste site, pipeline or facility. However, many waste site remedies are different between the ROD for 100-DR-1, DR-2, HR-1, HR-2 and HR-3 OUs, July 2018, and DOE/RL-88-30, Rev. 28, February 2019. Although the February 2019 document is more recent, the ROD remedy was selected for waste sites where there was a difference.

5. For the ICs only remedy for waste sites in the ROD for 100-DR-1, DR-2, HR-1, HR-2 and HR-3 OUs, July 2018, the LTS remedy was used in the RDD, even though the Remedy Crosswalk (3/25/15), which is the guide for assigning remedies in the RDD, indicates that LTS is for structures and not for waste sites.

6. For documents such as letters and TPA Change Notices which modify RDDs, it is suggested to handle them as the document type of the RDD being changed, following these three examples:

a. Several letters (Doc ID #s 169, 173 and 174) documented that 200-MG-1 Operable Unit waste sites OCSA, UPR-600-12 and 216-S-16D, which all had selected remedies of CS/NFA under the RAWP (Doc ID #58), had sample results that exceeded the removal action levels so the remedy should be changed to RTD. The letters were treated as revisions to the RAWP and the basis for changing the selected remedy for these waste sites.

b. TPA Change (Doc ID #172) documented that 21 non-contaminated septic waste systems would be removed from the 200-MG-1 Operable Unit since they do not need to be closed under CERCLA or RCRA and would be closed under Washington State Department of Health requirements. The TPA Change was treated as a revision to the ROD and the basis for changing the operable unit (to not applicable) and the selected remedy for these septic sites (based on the state requirements for void fill).

c. TPA Change (Doc ID #170) added 19 facilities to the RAWP (Doc ID #77). The TPA Change was treated as a revision to the RAWP and the basis for the selected remedy of D4 for these facilities.

Regulatory Decision Document Database Desk Instruction

PFM-00164

17 January 2020

APPENDIX A Definitions: Regulatory Decision Documents

Term Definition

Action Memorandum (AM)

The AM documents the results of the EE/CA and the response decision for all non-time-critical removal actions under CERCLA.

Administrative Record (AR)

The Tri-Party Agreement (TPA) Administrative Record (AR) (http://pdw.hanford.gov/arpir/) includes the body of documents and information that is considered or relied upon in order to arrive at a final decision or remedial action. A list of required AR documents is included in Tri-Party Agreement Table 9-3 (http://www.hanford.gov/files.cfm/ap-sec-9.pdf).

Cleanup Planning Map The Cleanup Planning Map application can be accessed from the Hanford Geographic Information System (HGIS) website (http://hgis.rl.gov/hgis/). This application has several unique data layers, including RDD status for facilities and waste sites, Baseline Cleanup Remedy, RDD Remedy, WIDS waste sites by Operable Unit and Facility Overall Asset Condition. The application also includes more query fields including the ability to filter results using Implementation Areas, Subsequent Units for Individual Development (SqUID) or Operable Units, and it contains several custom built-in queries (i.e., workflows) under the “I want to…” tab to facilitate user-specified queries. This application replaced the GeoVis application in 2018.

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)

A Federal law passed in 1980 that established Federal authority for responding to the release of hazardous substances into the environment including creating a Federal fund to finance responses and imposing liability for releases on the responsible parties. CERCLA was amended in 1986 by the Superfund Amendments and Reauthorization Act (SARA).

Corrective Action Decision (CAD)

The RCRA CAD corresponds to the CERCLA ROD. Under the TPA, the Washington State Department of Ecology (Ecology) is the lead regulatory agency for CAD documents and will evaluate all decisions to determine that Washington Administrative Code (WAC) 173-303-64620(4) standards are met.

Corrective Action Work Plan (CAWP)

The RCRA CAWP corresponds to the CERCLA RD/RAWP. The CAWP includes detailed plans that include design and performance specifications, complete construction drawings, and operational plans for the corrective measure.

Corrective Measures Study (CMS)

The RCRA CMS corresponds to the CERCLA FS. If the RFI results in a finding that there is a need to implement a corrective measure, the CMS serves as a focused examination of the alternatives for the corrective measure.

Regulatory Decision Document Database Desk Instruction

PFM-00164

18 January 2020

Term Definition

Engineering Evaluation/Cost Analysis (EE/CA)

The EE/CA identifies the objectives of the CERCLA removal action and analyzes the effectiveness, implementability, and cost of various alternatives that may satisfy these objectives. The EE/CA serves an analogous function to, but is more streamlined than, the Remedial Investigation/Feasibility Study (RI/FS) conducted for remedial actions.

Explanation of Significant Difference (ESD)

Changes to the remedy selected in the ROD that occur during the RD/RA process must be described in an ESD (for a significant change) or ROD Amendment (for a fundamental change) pursuant to the National Contingency Plan (NCP) §§300.435(c)(2) and 300.825(a).

Feasibility Study (FS) The Feasibility Study Report is the culmination of the individual Phases (I, II, & III). Phase I of the Feasibility Study is an iterative process with Phase I and II of the Remedial Investigation. During Phase I development of remedial alternatives an appropriate range of waste management options is developed that will be analyzed fully in Phase II and Phase III. In FS Phase II, Alternatives Screening, the alternatives identified in Phase I are analyzed to investigate interactions among media in terms of both the evaluation of technologies and site wide protectiveness. Phase III, Alternative Selection, is the detailed analysis of the screened-in alternatives from Phase II.

Hanford Maps (HMAPS) HMAPS is a Hanford Local Area Network (HLAN) web-based tool that allows non-technical Geographic Information Systems (GIS) users to access and search web-based maps and link them with pertinent business data to enable better project planning and decision making.

Integrated Data Management System (IDMS)

IDMS is a Hanford Local Area Network (HLAN) web-based tool for developing, storing and retrieving documents and other records generated at Hanford. This includes sensitive unclassified information.

National Environmental Policy Act (NEPA)

A Federal law passed in 1969 that established a U.S. national policy promoting the enhancement of the environment and procedural requirements for all federal government agencies to prepare environmental assessments (EAs) and environmental impact statements (EISs) that contain statements of the environmental effects of proposed federal agency actions. Under DOE’s CERCLA/NEPA Policy, established in 1994, DOE relies on the CERCLA process for review of actions to be taken under CERCLA so that no separate NEPA document or NEPA process is ordinarily required. Actions taken under RCRA may require a separate NEPA review.

Operations and Maintenance Plan (OMP)

The OMP ensures that the remedy continues to perform as intended and remains protective of human health and the environment. The OMP addresses activities that may include remedy operation, maintenance and monitoring, as well as monitoring of impacted media.

Regulatory Decision Document Database Desk Instruction

PFM-00164

19 January 2020

Term Definition

Performance Monitoring Plan (PMP)

The PMP identifies the objectives, schedules, reporting requirements, sampling strategies, technologies, and personnel necessary to ensure remedy effectiveness.

Proposed Plan (PP) The Proposed Plan is based on the information provided and decisions made during the Remedial Investigation and Feasibility Study phase. The Proposed Plan is DOE’s primary recommendation on how to best address contamination at the site, presents evaluated alternatives and reasoning behind the preferred alternative.

RCRA Facility Investigation (RFI)

The RFI is a detailed investigation to determine the nature, extent, and migration rate of the release, if any, and to provide information necessary for developing a strategy for addressing contamination. While similar to the CERCLA RI, the RFI is more focused and generally pertains to characterization of releases from Solid Waste Management Units (SWMUs), rather than characterization of the entire facility.

Record of Decision (ROD) The Record of Decision is a legal document that certifies the remedy selection process was carried out in accordance with CERCLA and, to the extent practicable, in accordance with the NCP. The ROD outlines the decision based on the nine CERCLA evaluation criteria and statutory requirements. It reassesses the initial determination of the preferred alternatives factoring in any new information or concerns expressed by regulators and public. The ROD must document all responses to comments and substantiate any changes to the selected remedial alternative as presented in the Proposed Plan. At the Hanford Site all RODs are jointly signed by DOE and EPA, with concurrence as appropriate by Ecology management. Upon issue to the TPA AR, DOE must publicize public availability of the ROD.

Regulatory Decision Document (RDD)

An RDD is a document that supports, documents, or implements the regulatory removal, remedial or corrective action decision for environmental cleanup objects (e.g. waste site, facility, pipeline, or groundwater) at the Hanford Site.

Remedial Design/Remedial Action Work Plan (RD/RAWP)

The RD/RAWP is the implementation plan for the Remedial Design Report (RDR), the final design document detailing the remedy selected in the ROD. The RD/RAWP is developed following issuance of the CERCLA ROD and lays out the approach and schedule for design and implementation of the remedial actions.

Remedial Investigation (RI)

The RI report is developed upon completion of Phase I (Site Characterization) and Phase II (Treatability Study) of the Remedial Investigation. RI Phase I and Phase II can typically occur congruently with Phase I and Phase II of the Feasibility Study. The site characterization includes four main components; field investigation, sample analysis/validation, data evaluation and baseline risk assessment.

Regulatory Decision Document Database Desk Instruction

PFM-00164

20 January 2020

Term Definition

Removal Action Work Plan (RAWP)

The RAWP is the implementation plan for the AM in the CERCLA removal action process. It is similar in function to the RD/RAWP in the CERCLA remedial action process.

Resource Conservation and Recovery Act (RCRA)

A Federal law passed in 1976 that established a permit process for all facilities that treat, store, or dispose of hazardous wastes. EPA has authorized Washington State to administer parts of the RCRA permit program, which at the Hanford Site is implemented by Ecology.

Sampling and Analysis Plan (SAP)

A SAP documents the procedural and analytical requirements for collection of water, soil, sediment, or other samples taken to characterize areas of potential environmental contamination. It combines the basic elements of a Quality Assurance Project Plan (QAPP) and a Field Sampling Plan (FSP).

State Environmental Policy Act (SEPA)

Enacted by the Washington Legislature in 1971 and modeled after NEPA, the State Environmental Policy Act (SEPA) helps state and local agencies in Washington identify possible environmental impacts that could result from governmental decisions.

Treatability Test Plan (TTP)

The TTP describes the remedy screening, remedy-selection testing or remedial design/remedial action testing in a systematic and stepwise fashion to determine the effectiveness of a technology (or combination of technologies) in remediating a CERCLA site.

Tri-Party Agreement (TPA)

A legally binding Federal Facilities Agreement between U.S. EPA, Washington Department of Ecology and U.S. Department of Energy in response to the Hanford Site being placed on the National Priorities List. The TPA Action Plan outlines how RCRA and CERCLA cleanup should proceed and how interactions between the three agencies should be coordinated. It is a continuously evolving but legally binding document. The TPA Action Plan is the executable portion of the agreement.

Waste Control Plan / Waste Management Plan (WCP/WMP)

The WCP/WMP establishes the requirements for management and disposal of waste associated with remedial or removal actions at Hanford Site groundwater Operable Units.