U.S. Department of Energy’s Consolidated Audit Program George E. Detsis Manager, Analytical Services Program Office of Corporate Safety Programs, HS-31 Presented before the 2008 Second Annual RadWaste Summit September 2-5, 2008 Las Vegas, Nevada

Presentation Outline Program Overview Program Overview Background (IG/GAO) Background (IG/GAO) Checklists Checklists Common Findings Common Findings Accomplishments/Challenges Accomplishments/Challenges

Overview of Analytical Services Program

Finding from DOE’s Office of the Inspector General and GAO Reports Report on the Audit of DOE’s Commercial Laboratory Quality Assurance Evaluation Program (June 1995) IG and GAO Identified reductions in DOE Auditing and Contracting of Analytical Services Some laboratories were audited numerous times; others were never audited Some laboratories were audited numerous times; others were never audited Evaluation methods varied significantly from one contractor to another Evaluation methods varied significantly from one contractor to another Audit results were not shared between contractors Audit results were not shared between contractors

DOECAP Background Purpose: Reduction audit redundancies Reduction audit redundancies Standardize audit methodology, policies and procedures Standardize audit methodology, policies and procedures Communicate Lessons Learned Communicate Lessons Learned Reduce overall Department risks/liabilities Reduce overall Department risks/liabilities Contractual agreement linkage Contractual agreement linkage Involves all DOE line organizations/field operations Involves all DOE line organizations/field operations Auditor participants primarily DOE contractor holders Auditor participants primarily DOE contractor holders Auditor qualifications/training requirements Auditor qualifications/training requirements Federal staff lead TSDF audits Federal staff lead TSDF audits

Results of Formalized DOE Auditing Program DOECAP reduced the Department’s risks and liabilities, and verified radioactive and chemical waste accountability DOECAP reduced the Department’s risks and liabilities, and verified radioactive and chemical waste accountability FYO8 DOECAP Auditing Activities: FYO8 DOECAP Auditing Activities: 30 Analytical Environmental Laboratories 1 Laboratory Surveillance 1 Laboratory Surveillance 7 TSDF’s 7 TSDF’s 1 Non-radiological TSDF scoping 1 Non-radiological TSDF scoping

Criteria Definitions Priority I Finding Programmatic/systematic failure Programmatic/systematic failure Imminent threat to worker safety/health Imminent threat to worker safety/health Potential for major property/facility damage Potential for major property/facility damage Repeated deficiency Repeated deficiency Priority II Finding Nonconformance with internal requirements/procedures Nonconformance with internal requirements/procedures Undocumented procedures Undocumented procedures Nonconformance with DOE requirements Nonconformance with DOE requirements Observation Isolated instance/deficiency Isolated instance/deficiency Opportunity for improvement Opportunity for improvement

Audit Checklists Module 1 – Quality Assurance Management Systems Module 2 – Sampling and Analytical Data Quality Module 3 – Waste Operations Module 4 – Environmental Compliance and Permitting Module 5 – Radiological Control Module 6 – Industrial & Chemical Safety Module 7 – Transportation Management

Audit Driver DOE Order (manual), Radioactive Waste Management DOE Order (manual), Radioactive Waste Management Requires that DOE first utilize DOE facilities to manage radioactive waste Requires that DOE first utilize DOE facilities to manage radioactive waste However, if DOE chooses to use a non-DOE waste vendor, DOE must perform an annual ES&H review However, if DOE chooses to use a non-DOE waste vendor, DOE must perform an annual ES&H review

Perspective/Context All 7 TSDFs were found to maintain the established management systems and operational activities necessary to meet DOE requirements for the storage, handling, transportation, processing and final disposition of DOE waste.

Percent Distribution of FY 2008 TSDF Findings

Percent Distribution of FY 2008 TSDF Observations

TSDFs Audited in FY08 Diversified Scientific Services, Inc. (DSSI), Kingston, TN Energy Solutions, LLC, Oak Ridge, TN Energy Solutions of Utah, Clive, Utah Materials and Energy Corporation, Oak Ridge, TN Perma-Fix Northwest, Richland, WA Perma-Fix of Florida, Gainesville, FL Waste Control Specialists, Andrews, TX

Common TSDF Findings by Audit Discipline (FY 08) Quality Assurance Management Systems: Quality Assurance Management Systems: Follow-up on corrective actions Follow-up on corrective actions SOP reviews are not current SOP reviews are not current Training records are not complete Training records are not complete Document control is inadequate Document control is inadequate Sampling and Analytical Data Quality: Sampling and Analytical Data Quality: Waste Analysis Plan Discrepancies Waste Analysis Plan Discrepancies Incomplete SOPs Incomplete SOPs Waste Operations: Waste Operations: Excessive quantities of aged waste on site Excessive quantities of aged waste on site Actual work practice not consistent with SOP or Plan Actual work practice not consistent with SOP or Plan

Common TSDF Findings by Audit Discipline (FY 08) cont’d Environmental Compliance/Permitting: Environmental Compliance/Permitting: Container label, designation or storage condition inadequate Container label, designation or storage condition inadequate Shipment receipt verification incomplete Shipment receipt verification incomplete Area inspections and documentation inadequate Area inspections and documentation inadequate Performing a waste size reduction process without having regulatory approval (one instance) Performing a waste size reduction process without having regulatory approval (one instance) Radiological Control: Radiological Control: Radiological work permit briefing and training inadequate Radiological work permit briefing and training inadequate Inappropriate monitoring instruments for alpha Inappropriate monitoring instruments for alpha Visitor monitoring and training inadequate Visitor monitoring and training inadequate Inadequate posting or signage Inadequate posting or signage

Common TSDF Findings by Audit Discipline (FY 08) cont’d Industrial and Chemical Safety: Industrial and Chemical Safety: Inadequate Health and Safety Plans or delinquent reviews Inadequate Health and Safety Plans or delinquent reviews Postings for confined space incomplete Postings for confined space incomplete Incompatible chemical storage Incompatible chemical storage Inadequate chemical labeling Inadequate chemical labeling Transportation Management: Transportation Management: Lack of training Lack of training Records Management not included for all documents Records Management not included for all documents Evaluation of sub-tier contractor incomplete Evaluation of sub-tier contractor incomplete Incomplete shipping/receiving documentation Incomplete shipping/receiving documentation

TSDF Accomplishments Completed 7 TSDF audits; 1 on-site scoping of non- radiological TSDF Completed 7 TSDF audits; 1 on-site scoping of non- radiological TSDF Approved 7 TSDF Corrective Action Plans Approved 7 TSDF Corrective Action Plans Tracked 86% of FY2007 Corrective Actions to completion (57 FY2007 findings closed out of 66 identified) Tracked 86% of FY2007 Corrective Actions to completion (57 FY2007 findings closed out of 66 identified) Updated all Program audit checklists Updated all Program audit checklists Increased number of qualified auditors and lead auditors Increased number of qualified auditors and lead auditors Continued interagency partnering with EPA, State Agencies, and DoD Continued interagency partnering with EPA, State Agencies, and DoD

DOECAP Challenges Increase Federal team leaders Increase Federal team leaders Increase auditor pool Increase auditor pool Radiological control Radiological control Industrial and chemical safety Industrial and chemical safety Improve POCs active participation -- HQ/field Improve POCs active participation -- HQ/field Improve localized/regional auditor participation to reduce travel costs Improve localized/regional auditor participation to reduce travel costs Improve program ownership/responsibility Improve program ownership/responsibility Increase incorporation of DOECAP language into contracts Increase incorporation of DOECAP language into contracts

ASP Program Contact Information George Detsis, Analytical Services Program (ASP) Manager Phone: (301) Carolyne Thomas - DOECAP Manager, DOE Oak Ridge Phone: (865) Guy Marlette, MAPEP Coordinator, Idaho National Laboratory Phone: (208) Brent Pulsifer, VSP Coordinator, Pacific Northwest National Laboratory Phone: (509)