u.s. epa inspector general audit reports
DESCRIPTION
DOE EM-5 DQO Training Workshop - Day 1 Appendix B. U.S. EPA Inspector General Audit Reports. EPA Inspector General Audit Reports. Objectives: To highlight important findings from EPA Inspector General Audit Reports. - PowerPoint PPT PresentationTRANSCRIPT
11 of 22 of 22
U.S. EPA Inspector General U.S. EPA Inspector General Audit ReportsAudit Reports
DOE EM-5 DQO Training WorkshopDOE EM-5 DQO Training Workshop - Day 1- Day 1Appendix BAppendix B
22 of 22 of 22
EPA Inspector General Audit EPA Inspector General Audit ReportsReports
Objectives:Objectives:– To highlight important findings from EPA To highlight important findings from EPA
Inspector General Audit Reports.Inspector General Audit Reports.– To underscore the fact that the EPA Regions To underscore the fact that the EPA Regions
do not have a strong record of using the DQO do not have a strong record of using the DQO Process as designed in QA/G-4.Process as designed in QA/G-4.
– To present EPA’s new commitment to a To present EPA’s new commitment to a systematic planning process for environmental systematic planning process for environmental decision-making.decision-making.
33 of 22 of 22
Environmental Death PenaltyEnvironmental Death Penalty
Site Delisted
44 of 22 of 22
Sacramento Army DepotSacramento Army Depot
Inspector General Inspector General recommended that recommended that EPA Region 9 EPA Region 9 Administrator:Administrator:– ““Inform the Army that Inform the Army that
the cleanup certification the cleanup certification for the Tank 2 Operable for the Tank 2 Operable Unit is being Unit is being withdrawn…”withdrawn…”
US EPA OIG, 1995, Environmental Data Quality at DOD Superfund Sites in Region 9,
E1SKF5-09-0031-05100505, September 26, 1995; page 40
55 of 22 of 22
EPA Inspector General EPA Inspector General ReportsReports
Environmental Data Quality at DOD Environmental Data Quality at DOD Superfund Sites in Region 9 - 1995Superfund Sites in Region 9 - 1995
Laboratory Data Quality at Federal Facility Laboratory Data Quality at Federal Facility Superfund Sites - 1997Superfund Sites - 1997
Environmental Data Quality at Superfund Environmental Data Quality at Superfund Removal Actions in Region 9 - 1998Removal Actions in Region 9 - 1998
EPA Had Not Effectively Implemented Its EPA Had Not Effectively Implemented Its Superfund Quality Assurance Program - Superfund Quality Assurance Program - 19981998
EPA OIG Web Site: http://www.epa.gov/oigearth/oarept.htm
EPA IG conducted audits of EPA cleanup activities and issued the following reports:
66 of 22 of 22
EPA Inspector General ReportsEPA Inspector General Reports
Purpose of AuditsPurpose of Audits– To determine if data was of known and To determine if data was of known and
acceptable quality and quantity to support acceptable quality and quantity to support the environmental decision making the environmental decision making process.process.
77 of 22 of 22
General FindingsGeneral Findings
Found Deficiencies in EPA’s:Found Deficiencies in EPA’s:– Decision-Making Process/ProceduresDecision-Making Process/Procedures– Consideration of AlternativesConsideration of Alternatives– Decision CriteriaDecision Criteria– DocumentationDocumentation
88 of 22 of 22
Wasted Time and MoneyWasted Time and Money
“…“…the Region completed 5 removal the Region completed 5 removal actions, costing more than $20 million, actions, costing more than $20 million, without sufficiently documenting decision without sufficiently documenting decision criteria or alternatives.”criteria or alternatives.”
The lack of decision criteria or performance The lack of decision criteria or performance specifications for decision making means specifications for decision making means DQOs were not done properly, correctly, or DQOs were not done properly, correctly, or at all.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.
99 of 22 of 22
Insufficient ProceduresInsufficient Procedures
““Our audit of nine Federal facility Our audit of nine Federal facility Superfund sites in EPA Regions 8, 9, Superfund sites in EPA Regions 8, 9, and 10 showed that EPA and Federal and 10 showed that EPA and Federal facilities did not have sufficient facilities did not have sufficient procedures in place to ensure that data procedures in place to ensure that data was of known and acceptable quality.”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
1010 of 22 of 22
DQOs Not UsedDQOs Not Used
““...the Region did not fully use EPA’s ...the Region did not fully use EPA’s scientific planning process, called scientific planning process, called DQOs, to ensure its removal actions DQOs, to ensure its removal actions and corresponding data collection and corresponding data collection activities were effective and efficient.”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
1111 of 22 of 22
DQOs Not DevelopedDQOs Not Developed
“…“…at a California Superfund...EPA spent at a California Superfund...EPA spent over $2 million in oversight costs and the over $2 million in oversight costs and the responsible party spent over $100 million responsible party spent over $100 million on studies and cleanup. However, the on studies and cleanup. However, the project plan showed that the potentially project plan showed that the potentially responsible party had not developed responsible party had not developed adequate data quality objectives...”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
1212 of 22 of 22
DQOs Not DevelopedDQOs Not Developed
““The OIG concluded that Superfund The OIG concluded that Superfund managers were not consistently managers were not consistently implementing EPA’s policy to develop implementing EPA’s policy to develop data quality objectives (DQOs) for data quality objectives (DQOs) for environmental data collection environmental data collection activities.” activities.”
US EPA OSWER, 1999, OSWER Quality Assurance Initiatives and Recommendations for Regional Implementation,
Memorandum, June 17, 1999
1313 of 22 of 22
Reasons DQOs Were Reasons DQOs Were Not Used By EPA:Not Used By EPA:
DQOs were not considered mandatoryDQOs were not considered mandatory Lack of DQO training and experienceLack of DQO training and experience Perception that DQOs were not Perception that DQOs were not
practicalpractical Process to support DQOs not in placeProcess to support DQOs not in place
1414 of 22 of 22
Changes Needed to Support Changes Needed to Support EPA’s DQO Process:EPA’s DQO Process:
Require DQOsRequire DQOs Set training requirementsSet training requirements Use a team approachUse a team approach Designate facilitatorsDesignate facilitators Emphasize importance of planningEmphasize importance of planning Consistent implementation processConsistent implementation process Standardized documentation formatsStandardized documentation formats
1515 of 22 of 22
OSWER Directive, OSWER Directive, June 17, 1999June 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
1616 of 22 of 22
Issue 1:Issue 1: Systematic Planning/Data Quality Systematic Planning/Data Quality ObjectivesObjectives
EPA “not consistently implementing EPA’s policy to develop data quality objectives (DQOs) for environmental data collection activities.
The 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.”
US EPA OSWER, 1999, OSWER Quality Assurance Initiatives and Recommendations for Regional Implementation,
Memorandum, June 17, 1999
1717 of 22 of 22
Institutionalize DQOsInstitutionalize DQOs
OIG RecommendationOIG Recommendation: “In concert with : “In concert with QAD, develop and implement a plan to QAD, develop and implement a plan to institutionalize the Superfund program’s institutionalize the Superfund program’s data quality objectives process.”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
1818 of 22 of 22
OSWER/OERR ResponseOSWER/OERR Response::
“...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
1919 of 22 of 22
Systematic Planning ProcessSystematic Planning Process
““It is critical for the Regions to proactively It is critical for the Regions to proactively endorse, follow, and document a endorse, follow, and document a systematic systematic planning processplanning process…”…”
US EPA OSWER, 1999, OSWER Quality Assurance Initiatives and Recommendations for Regional Implementation,
Memorandum, June 17, 1999
2020 of 22 of 22
Hanford ModelHanford Model
““Our audit of …Federal Facility Superfund Our audit of …Federal Facility Superfund Sites …found that the Hanford NuclearSites …found that the Hanford Nuclear Reservation had developed an effective Reservation had developed an effective DQO implementation procedure.”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
2121 of 22 of 22
Contacts:Contacts:
Sebastian C. Tindall Sebastian C. Tindall Bechtel Hanford Inc.Bechtel Hanford Inc.
509-372-9195 509-372-9195 3350 George Washington Way, HO-3350 George Washington Way, HO-0202
[email protected] [email protected] Richland, WA 99352Richland, WA 99352
Elizabeth M. (Liz) BowersElizabeth M. (Liz) Bowers Department of Energy Department of Energy
509-373-9276 509-373-9276 825 Jadwin Avenue, A2-15825 Jadwin Avenue, A2-15
[email protected] [email protected] Richland, WA 99352Richland, WA 99352
James R. Davidson, Jr. James R. Davidson, Jr. Davidson & Davidson, Inc.Davidson & Davidson, Inc.
509-374-4498 509-374-4498 2400 Stevens Drive, K5-122400 Stevens Drive, K5-12
[email protected] [email protected] Kennewick, WA 99336Kennewick, WA 99336
2222 of 22 of 22
End of ModuleEnd of Module