1. DoD Environmental Data Quality Workgroup Update Presented to: Joint Services Environmental Management Conference April 2005 Edward Hartzog Director, NAVSEA Laboratory Quality & Accreditation Office Chair, DoD EDQW DoD Representative, IDQTF

2. Topics OverviewOverview Key Quality Systems DriversKey Quality Systems Drivers Policy and GuidancePolicy and Guidance Quality Systems ImplementationQuality Systems Implementation –Joint Laboratory Oversight –Perchlorate Sampling and Testing –Training and Outreach

3. Data Quality Issues Affect Mission & Operations Environmental decisions are based on sampling and testing data Environmental decisions are based on sampling and testing data 95% of DoD lab testing is outsourced 95% of DoD lab testing is outsourced Requirements vary at federal, state, local levels Requirements vary at federal, state, local levels DoD has unique issues (e.g. emerging contaminants, munitions, vessel discharges) DoD has unique issues (e.g. emerging contaminants, munitions, vessel discharges)

4. DoD Inspector General Audit Report, Feb ‘97 Laboratory Support Services for Environmental Testing Audit Results Audit Results –“Organizations reviewed were not efficient and effective in the procurement and administration of environmental testing contracts” Recommendations Recommendations –Consolidate requirements of environmental tests –Develop standardized quality assurance procedures –Establish adequate procedures to administer contractor performance –Include government remedy clauses in environmental testing contracts

5. EPA Inspector General Report, Sept ‘98 Superfund Quality Assurance Program (Regions 1-10) Audit Results Audit Results –EPA had developed many critical elements necessary for a strong and effective QA program BUT –Managers had not demonstrated commitment to fully develop and implement the program Recommendations Recommendations –Design a strategy to institutionalize QA agency-wide –Improve oversight –Develop minimum QA requirements project planning, oversight, training, tools/resources, authority

6. Overview - EDQW Established by DUSD(ES) 1996, Navy chairEstablished by DUSD(ES) 1996, Navy chair Members: Army, Navy, Air Force, DLA, OSDMembers: Army, Navy, Air Force, DLA, OSD Tasks:Tasks: –Develop and recommend DoD policy for environmental data quality –Respond to legislative/regulatory initiatives –Represent DoD on Intergovernmental work groups (e.g. IDQTF, NELAC) –Respond to DoD IG recommendations Ensure the generation of environmental data of known and documented quality

7. Overview - EDQW Organization Principal (voting) representativesPrincipal (voting) representatives –Ed Hartzog – Navy (acting chair) –Rosemary Gaffney – Army (USACHPPM) –Tim Mukoda – Air Force (SAF/IEE) OSD Liaison – Ed MillerOSD Liaison – Ed Miller Technical representativesTechnical representatives –Laboratory Oversight, lead – Fred McLean (NAVSEA) –Quality Systems Implementation, lead – Skip Darley (NAVSEA) –Data Review and Management, lead – Dave Koran (HQ – USACE) Contractor supportContractor support –Perot Systems Government Services –Versar, Inc.

8. Overview - IDQTF Established by EPA 1997, Federal Facility Restoration and Reuse Office (FFRRO) leadEstablished by EPA 1997, Federal Facility Restoration and Reuse Office (FFRRO) lead Members: OSWER, EPA QA Staff, EPA Regions, DOE, and DoDMembers: OSWER, EPA QA Staff, EPA Regions, DOE, and DoD Tasks:Tasks: –Respond to EPA IG reports –Develop written consensus agreements for environmental quality systems –Outline roles and responsibilities for data quality oversight at Federal facilities

9. Key Quality Systems Drivers DoD Information Quality Guidelines, Ensuring Quality of Information Disseminated to the Public by the Department of Defense DoD Information Quality Guidelines, Ensuring Quality of Information Disseminated to the Public by the Department of Defense Proposed DoD Instruction 4715.xx, Environmental Data Quality Assurance Proposed DoD Instruction 4715.xx, Environmental Data Quality Assurance Draft DoD Procurement Policy, Implementing Minimum QS Performance Standards into DoD Acquisitions Involving Environmental Sampling and Testing Draft DoD Procurement Policy, Implementing Minimum QS Performance Standards into DoD Acquisitions Involving Environmental Sampling and Testing

10. Data Quality Challenges Ensuring Quality of Information Disseminated to the Public by the Department of Defense, February 2003 InformationQuality Utility Information meets the needs of its intended users Objectivity Information is accurate, clear, complete, unbiased, and reliable Integrity Information is protected from unauthorized access or revision Data must be “capable of being substantially reproduced ”

11. Proposed DoD Instruction 4715.XX Environmental Data Quality Assurance Assigns responsibilities for implementing environmental quality systems Assigns responsibilities for implementing environmental quality systems Implements DoD Data Integrity Policy Implements DoD Data Integrity Policy Authorizes the publication of key Quality Systems documents Authorizes the publication of key Quality Systems documents Establishes programs to monitor progress in quality systems implementation Establishes programs to monitor progress in quality systems implementation Final Draft – December ‘04

12. Quality Systems Implementation DoD Procurement Policy Provides minimum performance standards for acquisitions involving environmental sampling and testing Provides minimum performance standards for acquisitions involving environmental sampling and testing Provides sample language to use in solicitations and contracts Provides sample language to use in solicitations and contracts Defines minimum qualifications for contractor quality assurance personnel Defines minimum qualifications for contractor quality assurance personnel Specifies prohibited laboratory practices Specifies prohibited laboratory practices Final Draft 17 March 2005

13. Quality Systems Policy & Guidance Uniform Federal Policy for Implementing Environmental Quality Systems (UFP-QS)Uniform Federal Policy for Implementing Environmental Quality Systems (UFP-QS) Uniform Federal Policy for Quality Assurance Project Plans (UFP-QAPP)Uniform Federal Policy for Quality Assurance Project Plans (UFP-QAPP) Federal Quality Systems Roles and Responsibilities Guidance (R&R)Federal Quality Systems Roles and Responsibilities Guidance (R&R) DoD Quality Systems Manual for Environmental Laboratories (DoD QSM, V3)DoD Quality Systems Manual for Environmental Laboratories (DoD QSM, V3)

14. UFP-QS Final Version 1, January 2003 Requirements and guidelines for documenting and implementing acceptable environmental quality systems (based on ANSI/ASQ E4-2004)Requirements and guidelines for documenting and implementing acceptable environmental quality systems (based on ANSI/ASQ E4-2004) Developed to ensure:Developed to ensure: Environmental data are of known and documented qualityEnvironmental data are of known and documented quality Data are suitable for their intended usesData are suitable for their intended uses Data collection and technology programs meet stated requirementsData collection and technology programs meet stated requirements Can be used to develop new quality systems or evaluate the adequacy of existing quality systemsCan be used to develop new quality systems or evaluate the adequacy of existing quality systems

15. UFP-QAPP Interim Final, July 2004 Promotes systematic planning; encourages ‘graded approach’ Promotes systematic planning; encourages ‘graded approach’ Provides instructions and worksheets for preparing project-planning documents Provides instructions and worksheets for preparing project-planning documents Establishes minimum QA/QC criteria for hazardous waste sites Establishes minimum QA/QC criteria for hazardous waste sites Streamlines development, review, and approval of project-planning documents Streamlines development, review, and approval of project-planning documents

16. DoD Quality Systems Manual for Environmental Laboratories (QSM V3) Defines DoD requirements for laboratories (based on NELAC standards, which are based on ISO/IEC 17025:1999)Defines DoD requirements for laboratories (based on NELAC standards, which are based on ISO/IEC 17025:1999) Unifies common elements of Army, Navy, and Air Force QSMsUnifies common elements of Army, Navy, and Air Force QSMs Provides basis for shared DoD assessments and oversightProvides basis for shared DoD assessments and oversight Addresses method performance criteria, laboratory ethics & prohibited practicesAddresses method performance criteria, laboratory ethics & prohibited practices https://www.denix.osd.mil/denix/denix.html

17. Federal Quality Systems R&R Guidance Final, July 2004 EPA HQ: Consistent quality systems implementation throughout EPA and statesEPA HQ: Consistent quality systems implementation throughout EPA and states EPA Regional offices: Consistent review and approval of QAPPsEPA Regional offices: Consistent review and approval of QAPPs Federal Departments/Agencies: Agency- specific quality systems implementationFederal Departments/Agencies: Agency- specific quality systems implementation IDQTF: Outreach and assistanceIDQTF: Outreach and assistance Concurrence expected March 2005

18. Quality Systems Implementation Laboratory OversightLaboratory Oversight Quality Assurance Handbook for Perchlorate InvestigationsQuality Assurance Handbook for Perchlorate Investigations Training and OutreachTraining and Outreach

19. Laboratory Oversight ‘NELAP Plus’ NELAP accreditation provides baseline laboratory credentialsNELAP accreditation provides baseline laboratory credentials DoD resources focused on assessment of conformance to DoD QSM and project-specific requirementsDoD resources focused on assessment of conformance to DoD QSM and project-specific requirements Components of DoD Laboratory Assessment Protocol include:Components of DoD Laboratory Assessment Protocol include: –Assessment checklists based on DoD QSM –Joint assessments –Laboratory assessment database

20. Perchlorate DoD Interim Policy (Sept 2003) Components must collect and compile perchlorate data for:Components must collect and compile perchlorate data for: –Drinking water supplies subject to Unregulated Contaminant Monitoring Rule (UCMR) –Wastewater discharges permitted under National Pollutant Discharge Elimination System (NPDES) –Environmental restoration sites where release may have occurred and complete human exposure pathway is likely to exist –Range assessments conducted under Munitions Action Plan and Defense Planning Guidance

21. Perchlorate: Data Quality Issues Most existing data based on various modifications of EPA Method 314.0Most existing data based on various modifications of EPA Method 314.0 –Method developed/validated for use in drinking water –Non-specific/subject to interferences –MRL in drinking water = 4 ppb –Not suitable for use in other matrices

22. Perchlorate: DoD Quality Assurance Handbook Guides preparation of project-planning documentsGuides preparation of project-planning documents Guides selection of appropriate methods and qualified laboratoriesGuides selection of appropriate methods and qualified laboratories Implements DoD Quality Systems Policy & GuidanceImplements DoD Quality Systems Policy & Guidance DoD Quality Assurance Handbook for PERCHLORATE Investigations Planning, Implementation, and Assessment Final Draft March 2005

23. DoD Quality Assurance Handbook Perchlorate Sampling and Testing Laboratories must comply with the DoD QSMLaboratories must comply with the DoD QSM Results above regulatory or action limit must be confirmed using perchlorate-specific technologyResults above regulatory or action limit must be confirmed using perchlorate-specific technology Ability to achieve MRL must be demonstrated in matrix of concernAbility to achieve MRL must be demonstrated in matrix of concern Selected methods must meet specified method performance criteria (MPCs)Selected methods must meet specified method performance criteria (MPCs)

24. DoD Quality Assurance Handbook Perchlorate Sampling and Testing Management and Review of Data Field documentation requirementsField documentation requirements Minimum requirements for laboratory data deliverable packagesMinimum requirements for laboratory data deliverable packages Internal and third-party data review proceduresInternal and third-party data review procedures

25. Quality Systems Implementation Training and Outreach ISEERB-approved training: Environmental Quality SamplingEnvironmental Quality Sampling Interagency UFP-QAPP TrainingInteragency UFP-QAPP Training NAVSEA 04XQ training: A2LA Laboratory Assessors NAVSEA 04XQ outreach: www.navylabs.navy.mil

26. DoD Environmental Monitoring and Data Quality (EM/DQ) Workshop Myrtle Beach, SC April 4 – 8 National forum for information exchangeNational forum for information exchange –Managing environmental data quality to support DoD mission and operations –Evolving policy, innovative strategies, technical tools TrainingTraining –DoD QSM – Understanding and Assessing the ‘Gray Boxes’ –DoD QSM Version 3 - Overview –Technical Implementation of SEDD

27. Sound Science: The Payoff The right data the first time The right data the first time - means the right decision the first time Reduced costs for compliance Reduced costs for compliance Streamlined restoration Streamlined restoration Reduced liability Reduced liability Sustained operational readiness Sustained operational readiness Public confidence Public confidence

28. HartzogEB@navsea.navy.mil (Acting EDQW Chair) www.navylabs.navy.mil www.denix.osd.mil/denix/DOD/Working/EDQW/edqw.html Improving Environmental Data Quality … Because the Right Decisions Require Quality Data