epa inspector general audit reports

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EPA Inspector General Audit Reports

15 minutes

DQO Training Course Day 1

Module 2

Presenter: Sebastian Tindall

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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

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Key Points

The EPA itself has not been implementing the DQO Process

The EPA has a new commitment to a systematic planning process for environmental decision making

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Environmental Death Penalty

Site Delisted

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Sacramento Army Depot 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the cleanup certification for the Tank 2 Operable Unit is being withdrawn…”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

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EPA Inspector General Reports

Environmental Data Quality at DOD Superfund Sites in Region 9 - 1995

Laboratory Data Quality at Federal Facility Superfund Sites - 1997

Environmental Data Quality at Superfund Removal Actions in Region 9 - 1998

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:

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EPA Inspector General Reports

Purpose of Audits

– To determine if data were of known and acceptable quality and quantity to support the environmental decision-making process

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General Findings Found Deficiencies in EPA’s:

– Decision-Making Process/Procedures

– Consideration of Alternatives

– Decision Criteria

– Documentation

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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.

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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

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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

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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

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Reasons DQOs Were Not Used By EPA:

DQOs were not considered mandatory Lack of DQO training and experience Perception that DQOs were not practical 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.

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Changes Needed to Support EPA’s DQO Process:

Require DQOs Set training requirements Use a team approach Designate facilitators Emphasize importance of planning Consistent implementation process Standardized documentation formats

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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

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“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

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Issue 1: Systematic Planning/Data Quality Objectives

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

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EPA OIG Recommendation: “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

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Office of Solid Waste and Emergency Response (OSWER)/Office of Emergency and Remedial Response (OERR) Response:

“...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.)

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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

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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

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Summary 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

EPA has responded that the problems will be fixed, in part, by requiring EPA Regions to perform systematic planning

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End of Module 2

Thank you

Questions?

We will now take a 15 minute break.Please be back in 15 minutes.