DQO Process History

1
DQO Training Course Day 1 Module 2
EPA Inspector General Audit Reports
Presenter Sebastian Tindall
(15 minutes)
2
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
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  for the Tank 2 Operable Unit is being withdrawn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
6
EPA Inspector General Reports
EPA IG conducted audits of EPA cleanup activities
and issued the following 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/oar
ept.htm
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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 EPAs
• 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.
10
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, EISKB6-09-0041-71001
32, March 20, 1997 page 1
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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.

Laboratory Data Quality at Federal Facility
Superfund Sites, US EPA OIG, EISKB6-09-0041-71001
32, March 20, 1997
12
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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DQOs Not Developed (cont.)

• The OIG concluded that Superfund managers were
  not consistently implementing EPAs 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
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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 EPAs 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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Issue 1 Systematic Planning/Data Quality
Objectives

• EPA not consistently implementing EPAs policy
  to develop data quality objectives (DQOs) for
  environmental data collection activities.
• The Office of the Inspector General (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.

OSWER Quality Assurance Initiatives and
Recommendations for Regional Implementation, US
EPA OSWER, Memorandum, June 17, 1999
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Institutionalize DQOs

• EPA OIG Recommendation
• In concert with QAD, develop and implement a
  plan to institutionalize the Superfund programs
  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
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Institutionalize DQOs (cont.)

• 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
20
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

• EPAs OIG found after several major audits of
  EPAs 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?