1. 1 of 22 U.S. EPA Inspector General Audit Reports DOE EM-5 DQO Training Workshop - Day 1 Appendix B

2. 2 of 22 EPA Inspector General Audit Reports n Objectives: –To highlight important findings from EPA Inspector General Audit Reports. –To underscore the fact that the EPA Regions do not have a strong record of using the DQO Process as designed in QA/G-4. –To present EPAs new commitment to a systematic planning process for environmental decision-making.

3. 3 of 22 Environmental Death Penalty Site Delisted

4. 4 of 22 Sacramento Army Depot n Inspector General recommended that EPA Region 9 Administrator: –Inform the Army that the cleanup certification for the Tank 2 Operable Unit is being withdrawn… US EPA OIG, 1995, Environmental Data Quality at DOD Superfund Sites in Region 9, E1SKF5-09-0031-05100505, September 26, 1995; page 40

5. 5 of 22 EPA Inspector General Reports l Environmental Data Quality at DOD Superfund Sites in Region 9 - 1995 l Laboratory Data Quality at Federal Facility Superfund Sites - 1997 l Environmental Data Quality at Superfund Removal Actions in Region 9 - 1998 l EPA Had Not Effectively Implemented Its Superfund Quality Assurance Program - 1998 EPA OIG Web Site: http://www.epa.gov/oigearth/oarept.htm EPA IG conducted audits of EPA cleanup activities and issued the following reports:

6. 6 of 22 EPA Inspector General Reports n Purpose of Audits –To determine if data was of known and acceptable quality and quantity to support the environmental decision making process.

7. 7 of 22 General Findings n Found Deficiencies in EPAs: –Decision-Making Process/Procedures –Consideration of Alternatives –Decision Criteria –Documentation

8. 8 of 22 Wasted Time and Money …the Region completed 5 removal actions, costing more than $20 million, without sufficiently documenting decision criteria or alternatives. The lack of decision criteria or performance specifications for decision making means DQOs were not done properly, correctly, or at all. US EPA OIG, 1998, Environmental Data Quality at Superfund Removal Actions in Region 9, E1SFF7-09-0058-8100223, September 4, 1998; page iii.

9. 9 of 22 Insufficient Procedures Our audit of nine Federal facility Superfund sites in EPA Regions 8, 9, and 10 showed that EPA and Federal facilities did not have sufficient procedures in place to ensure that data was of known and acceptable quality. US EPA OIG,1997, Laboratory Data Quality at Federal Facility Superfund Sites, EISKB6-09-0041-7100132, March 20, 1997; page 1

10. 10 of 22 DQOs Not Used...the Region did not fully use EPAs scientific planning process, called DQOs, to ensure its removal actions and corresponding data collection activities were effective and efficient. US EPA OIG, 1998, Laboratory Data Quality at Federal Facility Superfund Sites, E1SFF7-09-0058-8100223, September 4, 1998; memorandum

11. 11 of 22 DQOs Not Developed …at a California Superfund...EPA spent over $2 million in oversight costs and the responsible party spent over $100 million on studies and cleanup. However, the project plan showed that the potentially responsible party had not developed adequate data quality objectives... US EPA OIG, 1998, EPA Had Not Effectively Implemented Its Superfund Quality Assurance Program, E1SKF7-08-0011-8100240, September 30, 1998; pg 19

12. 12 of 22 DQOs Not Developed n The OIG concluded that Superfund managers were not consistently implementing EPAs policy to develop data quality objectives (DQOs) for environmental data collection activities. US EPA OSWER, 1999, OSWER Quality Assurance Initiatives and Recommendations for Regional Implementation, Memorandum, June 17, 1999

13. 13 of 22 Reasons DQOs Were Not Used By EPA: n DQOs were not considered mandatory n Lack of DQO training and experience n Perception that DQOs were not practical n Process to support DQOs not in place

14. 14 of 22 Changes Needed to Support EPAs DQO Process: n Require DQOs n Set training requirements n Use a team approach n Designate facilitators n Emphasize importance of planning n Consistent implementation process n Standardized documentation formats

15. 15 of 22 OSWER Directive, June 17, 1999 Subject: OSWER Quality Assurance Initiatives and Recommendations for Regional Implementation From:Timothy Fields, Jr. – –Acting Assistant Administrator To:- Assistant Regional Administrators - Superfund National Policy Managers - Regional, Science, and Technology Division Directors US EPA OSWER, 1999, OSWER Quality Assurance Initiatives and Recommendations for Regional Implementation, Memorandum, June 17, 1999

16. 16 of 22 Issue 1:Systematic Planning/Data Quality Objectives EPA not consistently implementing EPAs policy to develop data quality objectives (DQOs) for environmental data collection activities. n n The OIG attribute the lack of success for Superfunds formal development of DQOs to the lack of sufficient direction and tools. – –Please note that Order 5360.1, CHG 1, requires use of a systematic planning approach to develop acceptance or performance criteria for all work covered by this Order. US EPA OSWER, 1999, OSWER Quality Assurance Initiatives and Recommendations for Regional Implementation, Memorandum, June 17, 1999

17. 17 of 22 Institutionalize DQOs n OIG Recommendation: In concert with QAD, develop and implement a plan to institutionalize the Superfund programs data quality objectives process. US EPA OIG, 1998, EPA Had Not Effectively Implemented Its Superfund Quality Assurance Program, E1SKF7-08-0011-8100240, September 30, 1998; pg 19

18. 18 of 22 OSWER/OERR Response: n n...issuing this document to the Regions as a vehicle to institutionalize the data quality objective process for the Superfund program. US EPA OSWER, 1999, OSWER Quality Assurance Initiatives and Recommendations for Regional Implementation, Memorandum, June 17, 1999

19. 19 of 22 Systematic Planning Process n It is critical for the Regions to proactively endorse, follow, and document a systematic planning process… US EPA OSWER, 1999, OSWER Quality Assurance Initiatives and Recommendations for Regional Implementation, Memorandum, June 17, 1999

20. 20 of 22 Hanford Model Our audit of …Federal Facility Superfund Sites …found that the Hanford Nuclear Reservation had developed an effective DQO implementation procedure. US EPA OIG, 1998, Environmental Data Quality at Superfund Removal Actions in Region 9, E1SFF7-09-0058-8100223, September 4, 1998; page 21

21. 21 of 22 Contacts: n Sebastian C. Tindall Bechtel Hanford Inc. 509-372-9195 3350 George Washington Way, HO-02 sctindal@mail.bhi-erc.com Richland, WA 99352 n Elizabeth M. (Liz) BowersDepartment of Energy 509-373-9276 825 Jadwin Avenue, A2-15 Elizabeth_M_Liz_Bowers@RL.gov Richland, WA 99352 n James R. Davidson, Jr. Davidson & Davidson, Inc. 509-374-4498 2400 Stevens Drive, K5-12 davidson@owt.com Kennewick, WA 99336

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