1. 1 of 23 EPA Inspector General Audit Reports 15 minutes DQO Training Course Day 1 Module 2 Presenter: Sebastian Tindall

2. 2 of 23 Terminal Course Objective To highlight the general findings from EPA Inspector General Audit Reports and the problems created when the DQO Process is not followed

3. 3 of 23 Key Points n The EPA itself has not been implementing the DQO Process n The EPA has a new commitment to a systematic planning process for environmental decision making

4. 4 of 23 Environmental Death Penalty Site Delisted

5. 5 of 23 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that EPA Region 9 Administrator: –“Inform the Army that the cleanup certification for the Tank 2 Operable Unit is being withdrawn…” Environmental Data Quality at DOD Superfund Sites in Region 9, US EPA OIG, E1SKF5-09-0031-05100505, September 26, 1995; page 40

6. 6 of 23 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:

7. 7 of 23 EPA Inspector General Reports n Purpose of Audits –To determine if data were of known and acceptable quality and quantity to support the environmental decision- making process

8. 8 of 23 General Findings n Found Deficiencies in EPA’s: –Decision-Making Process/Procedures –Consideration of Alternatives –Decision Criteria –Documentation

9. 9 of 23 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. Environmental Data Quality at Superfund Removal Actions in Region 9, US EPA OIG, E1SFF7-09-0058-8100223, September 4, 1998; page iii.

10. 10 of 23 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.” Laboratory Data Quality at Federal Facility Superfund Sites, US EPA OIG, EISKB6-09-0041-7100132, March 20, 1997; page 1

11. 11 of 23 DQOs Not Used “...the Region did not fully use EPA’s scientific planning process, called DQOs, to ensure its removal actions and corresponding data collection activities were effective and efficient.” Laboratory Data Quality at Federal Facility Superfund Sites, US EPA OIG, EISKB6-09-0041-7100132, March 20, 1997

12. 12 of 23 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...” EPA Had Not Effectively Implemented Its Superfund Quality Assurance Program, US EPA OIG, E1SKF7-08-0011-8100240, September 30, 1998; pg 19

13. 13 of 23 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 Environmental Data Quality at Superfund Removal Actions in Region 9, US EPA OIG, E1SFF7-09-0058-8100223, September 4, 1998; page 9.

14. 14 of 23 Changes Needed to Support EPA’s 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 23 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 OSWER Quality Assurance Initiatives and Recommendations for Regional Implementation, US EPA OSWER, Memorandum, June 17, 1999

16. 16 of 23 “The OIG concluded that Superfund managers were not consistently implementing EPA’s policy to develop data quality objectives (DQOs) for environmental data collection activities.” OSWER Quality Assurance Initiatives and Recommendations for Regional Implementation, US EPA OSWER, Memorandum, June 17, 1999 Issue 1: Systematic Planning/Data Quality Objectives

17. 17 of 23 Issue 1: Systematic Planning/Data Quality Objectives n The Office of the Inspector General (OIG) “attribute the lack of success for Superfund’s 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.” OSWER Quality Assurance Initiatives and Recommendations for Regional Implementation, US EPA OSWER, Memorandum, June 17, 1999

18. 18 of 23 EPA OIG Recommendation: n “In concert with QAD, develop and implement a plan to institutionalize the Superfund program’s data quality objectives process.” EPA Had Not Effectively Implemented Its Superfund Quality Assurance Program, US EPA OIG, E1SKF7-08-0011-8100240, September 30, 1998; pg 19 Institutionalize DQOs

19. 19 of 23 Office of Solid Waste and Emergency Response (OSWER)/Office of Emergency and Remedial Response (OERR) Response: n “...issuing this document to the Regions as a vehicle to institutionalize the data quality objective process for the Superfund program.” OSWER Quality Assurance Initiatives and Recommendations for Regional Implementation, US EPA OSWER, Memorandum, June 17, 1999 Institutionalize DQOs (cont.)

20. 20 of 23 Systematic Planning Process “It is critical for the Regions to proactively endorse, follow, and document a systematic planning process…” OSWER Quality Assurance Initiatives and Recommendations for Regional Implementation, US EPA OSWER, Memorandum, June 17, 1999

21. 21 of 23 Hanford Model “ Our audit of …Federal Facility Superfund Sites …found that the Hanford Nuclear Reservation had developed an effective DQO implementation procedure.” Environmental Data Quality at Superfund Removal Actions in Region 9, US EPA OIG, E1SFF7-09-0058-8100223, September 4, 1998; page 21

22. 22 of 23 Summary n EPA’s OIG found after several major audits of EPA’s performance at several Federal Facility Superfund Sites that that was a serious danger of EPA having to put de-listed sites back on the National Priorities List (NPL) due to lack of defensible data and questionable decisions n EPA has responded that the problems will be fixed, in part, by requiring EPA Regions to perform systematic planning

23. 23 of 23 End of Module 2 Thank you Questions? We will now take a 15 minute break. Please be back in 15 minutes.