Corporate Overview Consolidated Auditing and Proficiency Testing Programs George E. Detsis Manager, Analytical Services Program Office of Environment, Health, Safety and Security Office of Sustainability Support 2014 ASER Workshop Los Alamos, New Mexico November 4-6, 2014

Topics Program accomplishments Common problems -- audit findings DOECAP lessons learned Future considerations

Accomplishments Implemented Department of Defense (DoD)/DOE Consolidated Quality Systems Manual (QSM) for Environmental Laboratories, and updated the Lab Audit Checklists 20 Lab Audits, which includes 1 Lab Surveillance and 4 Lab Closure Audits 8 Treatment, Storage, and Disposal Facility Audits Processed Corrective Action Plans Maintained a cadre of 134 trained volunteer auditors

Accomplishments (cont.) DOECAP TSDF Checklist Pilot – The facility completed the audit checklists in advance and self-identified deficiencies (treated DOECAP “SI” as observations rather than audit findings) Initiated a DOE Technical Standard on Lab Proficiency Testing (PT) Engaged DOE managers – Briefings on audit results/recruiting for auditor participation Analytical Services Program – FY 2013 Report

DOECAP Making a Difference Improving Lab/TSDF Performance Improved QA programs Reduction/elimination of legacy waste streams Corrective action plans that address “causal effects” to prevent reoccurrences Improving audit report quality – findings tied to requirements, specific requirements are cited, and the supporting evidence identified by the auditors is explained DoD/DOE Consolidated QSM improves the ability of Labs to prepare for Federal agency audits

Laboratory Audits

Distribution of FY 2014 Laboratory Findings

Common Problems -- FY 2014 Lab Findings Procedures, Procedures, Procedures Laboratory practices/SOPs do not accurately reflect the current analytical method Facilities lack the necessary SOPs Employees not trained to latest/approved procedures (lack of training documentation). Employees not following approved laboratory procedures Procedures not updated annually Not running quality control samples at required frequency Not maintaining equipment (preventive maintenance) and supplies (reagents/solvents) records. Not updating Quality Assurance Management Plan Opening incoming sample shipments outside of a ventilation hood, which means that personnel are potentially being exposed to hazardous materials.

Common Problems -- FY 2014 Lab Findings (cont.) Performing calculations associated with sample analysis using spreadsheets with formula cells that are not write-protected. Using acceptance criteria for analytical balances and pipettes that do not meet QSM requirements. Lack of analytical waste segregation, labeling , storage and disposal practices Lack of internal audits, and annual management review that fosters continuous improvements Logbook documentation issues

Tentative Laboratory Audit Schedule for FY 2015 Month & Year TestAmerica, Inc., Knoxville, TN November 2014 Eberline Analytical Corporation, Oak Ridge, TN December 2014 ALS Laboratory Group, Cincinnati, OH January 2015 Materials and Chemistry Laboratory, Inc., Oak Ridge, TN Shealy Environmental Services, Inc., West Columbia, SC February 2015 ALS Laboratory Group, Salt Lake City, UT American Radiation Services, Inc., Port Allen, LA March 2015 TestAmerica, Inc., Arvada, CO

Tentative Laboratory Audit Schedule for FY 2015 (cont.) Month & Year Southwest Research Institute, San Antonio, TX March 2015 GEL Laboratories, LLC, Charleston, SC April 2015 ALS Environmental Group, Fort Collins, CO May 2015 Shealy Consulting, LLC, Lexington, SC TestAmerica, Inc., Earth City, MO TestAmerica, Inc., Richland, WA June 2015 BC Laboratories, Inc., Bakersfield, CA Brooks Rand Labs, LLC, Seattle, WA

DOECAP TSDF Audits

Distribution of FY 2014 TSDF Findings

Common Problems -- FY 2014 TSDF Audit Findings Outbound shipping paperwork does not meet the requirements; for example: Technical Name requirements for hazardous material shipments Shipping Description and Hazard Class for hazardous material shipments Required content and signatures on outbound shipping papers Not ensuring that workers complete the required training for work under the hazardous waste management permit and/or failing to properly document completion of the required training.

Common Problems -- FY 2014 TSDF Audit Findings (cont.) Not meeting the requirements for: Chemical storage (incompatibles) Waste segregation Universal waste labeling and marking Failing to properly label measuring and test equipment with the calibration status.

Tentative TSDF Audit Schedule for FY 2015 Month & Year Clean Harbors Colfax, LLC, Colfax, LA November 2014 Clean Harbors Environmental Services – Deer Park, LaPorte, TX December 2014 Diversified Scientific Services, Inc., Kingston, TN January 2015 EnergySolutions, LLC, Oak Ridge, TN February 2015 Materials and Energy Corporation, Oak Ridge, TN March 2015 Perma-Fix Northwest, Inc., Richland, WA April 2015 EnergySolutions, LLC, Clive, UT Perma-Fix of Florida, Inc., Gainesville, FL May 2015 Waste Control Specialists LLC, Andrews, TX 9/12/2013, kb

DOECAP Lessons Learned Need to incorporate consistent DOE contract language for lab closures associated with the timeframe for waste disposition What will be the consequences of the Hanford Site Lab Closure? Taxpayer cost savings DOE will be farming that work out to other commercial labs

Mixed Analyte Performance Evaluation Program (MAPEP) Accomplishments 130 labs participation -- 88 domestic and 42 foreign Semiannual PT evaluations: MAPEP Series 30: Shipped March 2014 MAPEP Series 31: Shipped August 2014 (reporting deadline November 5 ,2014)

MAPEP Accomplishments (cont.) Initiated DOE - PT Technical Standard Performed special studies for uranium and strontium RMCC -- International collaborations – building lasting partnerships through science, not weapons

Uranium Isotopes Measurement by Alpha & Gamma Spectroscopy

Participation in MAPEP Improves Performance Laboratories’ performance for analysis of iodine‑129 in water

DOE Senior Management Support for MAPEP DOE Chief Health, Safety, and Security Officer memo on December 30, 2013, to program line and field element managers recommends that all onsite and sub- contracted environmental laboratories performing radiological, inorganic, or organic analyses for DOE be encouraged to participate in MAPEP.

Laboratory Audit Programs – Overall Objective The overall objective is to provide data of known, documented quality to field managers for use in making sound environmental management and cleanup decisions.

Future Considerations DOECAP Auditing Activities New labs being considered New non-radiological TSDFs being considered Budget considerations – FY 2015 budget remains flat

Future Considerations (cont.) Continuing TSDF Pilot Study of Self – Identified findings/completed checklists More focused DOECAP audit scopes: Laboratory Audit Disciplines Quality assurance Data quality for organic, inorganic, and radiochemistry analyses TSDF Audit Disciplines Environmental compliance and permitting Waste operations

Conclusion Flexibility Dealing with reorganizations, loss of institutional knowledge and changing priorities Maintaining excellence and consistency while continuing to provide value-added stakeholder benefits – risk reductions/performance improvements

George E. Detsis Office of Environment, Health, Safety and Security george.detsis@hq.doe.gov 301-903-1488

Questions? 9/20/2018