A Corporate Overview of the Analytical Services Program

1. A Corporate Overview of the Analytical Services Program George E. Detsis Manager, Analytical Services Program Office of Corporate Safety Programs, HS-31 ASER Workshop/ Environmental Monitoring Meeting 2008 Idaho Falls, Idaho October 6-9, 2008

2. Overview Analytical Services Program – 3 Component Elements - Auditing - Proficiency Testing - Data Collection Program Challenges Pipeline Program Contacts

3. Overview of Analytical Services Program

4. Finding from DOE’s Office of the Inspector General • Report on the Audit of DOE’s Commercial Laboratory Quality Assurance Evaluation Program (June 1995) • Some laboratories were audited numerous times; others were never audited • Evaluation methods varied significantly from one contractor to another • Audit results were not shared between contractors

5. DOE’s response to the IG Report • Eliminate redundant audits between various DOE field element sites • Perform two-thirds fewer audits • Resulting cost savings to taxpayer – $ 2.3 million • Standardized audit methodology and procedures • Quality Systems for Analytical Services (QSAS) • Audit checklists • Improved communications • Electronic Data System • Weekly Conference Calls • Annual Meeting/Annual Report

6. DOECAP Background • HSS-HQ funded/oversight/guidance/direction; DOE-ORO implementation • Program ownership – DOE line organizations and field operators • Not an approval or certification audit program • Volunteer auditors primarily DOE contractors/Federal TSDF team leaders/auditors

7. DOECAP Organizational Structure HSS Analytical Services Program Manager George Detsis Deputy DOECAP Manager Richard Martin DOECAP Manager Carolyne Thomas Operations Team Leader Nile Luedtke Technical Operations Coordinator Joe Pardue Corrective Actions Coordinator Susan Aderholdt Qualification Coordinator Todd Hardt Document Control Coordinator Rhonda Jobe

8. Results of FormalizedDOE Auditing Program DOECAP reduced the Department’s risks and liabilities through auditing analytical laboratories, and verified radioactive and chemical waste disposition FYO8 DOECAP Auditing Activities: 30 Analytical Environmental Laboratories 1 Laboratory Surveillance 7 TSDF’s 1 Non-radiological TSDF scoping

9. Criteria Definitions • Priority I Finding: • Programmatic/systematic failure • Imminent threat to worker safety/health • Potential for major property/facility damage • Repeated deficiency • Priority II Finding: • Nonconformance with internal requirements/procedures • Undocumented procedures • Nonconformance with DOE requirements • Observation: • Isolated instance/deficiency • Opportunity for improvement

10. What does this all mean? • DOECAP conducted 38 audits in FY2008 • 84% of all FY2007 audit findings were closed during FY2008: • 83% of the laboratory findings • 86% of the TSDF findings • New Findings Identified: • FY2006 = 233 • FY2007 = 340 • FY2008 = 218

11. Priority I Findings • Uranium - soil (1) • Antimony - soil (2) • Tetryl - soil/water (1) • Organochlorine pesticides - soil (1)

12. DOECAP Audit Checklists Laboratory Checklists TSDF Checklists • Checklist 1 – QA and General Laboratory Practices • Checklist 2 – Data Quality for Organic Analyses • Checklist 3 – Data Quality for Inorganic Analyses • Checklist 4 – Data Quality for Radiochemistry Analyses • Checklist 5 - Laboratory Information Management Systems/Electronic Data Management • Checklist 6 – Hazardous and Radioactive Materials Management • Checklist 7 – Geotechnical Measurements • Checklist 8 – Aquatic Toxicity • Checklist 9 – Non Destructive Assay • Checklist 10 – Laboratory Closures • Checklist 1 – Quality Assurance Management Systems • Checklist 2 - Sampling and Analytical Data Quality • Checklist 3 – Waste Operations • Checklist 4 – Environmental Compliance and Permitting • Checklist 5 – Radiological Control • Checklist 6 – Industrial & Chemical Safety • Checklist 7 – Transportation Management

13. Perspective/Context All 38 DOECAP audits conducted in FY08 were found to maintain the established management systems and operational activities necessary to meet DOE basic requirements for environmental data quality, and for the treatment and disposal of hazardous waste. However, DOECAP audits identified five Priority I findings at various analytical laboratories associated with multiple proficiency testing failures.

14. Distribution FY 2008 Priority II Lab Findings

15. FY00- FY08 Priority II Laboratory Findings

16. Analytical Laboratory Key Findings • Incomplete or inconsistent SOPs/Plans - not reviewed/updated on a timely basis - adherence - SOPs do not reflect approved laboratory practices • Inadequate training, and lack of training documentation - employee training requirements not met - employee training documentation files incomplete • Unacceptable performance testing results - ineffective corrective actions - root causes not addressed resulting in reoccurrence of PT failures

17. TENTATIVE FY09 LAB AUDIT SCHEDULE

18. Distribution FY 2008 Priority II TSDF Findings

19. FY00- FY08 Priority II TSDF Findings

20. TSDF Key Findings • Quality Assurance not following operating procedures training documentation • Environmental Compliance non-conformances with permit/regulatory requirements (e.g., aisle spacing, labeling, incompatible storage, waste identification, secondary containment, etc.) • Transportation Management incomplete paperwork tracking and filing shipments

21. TENTATIVE FY09 TSDF AUDIT SCHEDULE FacilityProposed Month Diversified Scientific Services, Inc November 18-20, 2008 Energy Solutions- Tennessee January 13-15, 2009 Materials and Energy Corporation February 2009 Perma-Fix Florida March 10-12, 2009 Energy Solutions – Utah April 2009 Perma-Fix Northwest May 2009 Waste Control Specialist June 2009

22. DOECAP Challenges • Increase number of Federal team leaders • Increase auditor pool - TSDFs (radiological control, and industrial and chemical safety) - Laboratories (laboratory information management systems/electronic data management, hazardous and radioactive materials management) • Improve POCs active participation -- HQ/field • Improve localization/regional auditor participation to reduce travel costs • Considerations for External Release of DOECAP Reports/Corrective Action Plans

23. DOECAP Challenges (Cont.) • Improve program ownership/responsibility • Incorporate DOECAP reference/requirement into DOE contract language • Incorporate DOECAP as a requirement in DOE Order Website: https://doecap.oro.doe.gov

24. MAPEP Background • Purpose: To test and evaluate environmental samples to provide defensible data that instills confidence in DOE decision-making • Program focus is radiological, stable inorganic, and organics - Media: soil, water, air filters, vegetation • QSAS Section 5.9, DOE-1 - MAPEP is required for all laboratories that perform radiochemical analyses for DOE - Accredited PT program for performing radiochemical, organic, or inorganic analyses • Program participation - 109 domestic analytical laboratories - 17 international laboratories Nuclear Test Ban Treaty New Zealand (1) Brazil (1) Cooperative Monitoring Canada (2) United Kingdom (2) Middle Eastern Nations Jordan (3) Iraq (1) Oman (1) Kuwait (1) Qatar (1) Turkey (1) Morocco (1) Israel (1) International Atomic Energy Agency (1)

25. MAPEP – Letters of Concern • MAPEP issues “Letters of Concern” to participants that demonstrate a performance trend that suggests there is a potential quality problem • The letters are issued to help ensure that the laboratory and its stakeholders are aware of the potential problem • Copies are sent to Points of Contact at DOE-HSS HQ, DOE Field Offices, Sample Management Offices, DOECAP, and other stakeholders

26. MAPEP – Letters of ConcernNumber of Letters Issued Compared to the Number of Participants • 45 Letters of Concern were issued after test session 18 among 124 participating laboratories • 45/124 = 36.3 % of participants received a Letter of Concern • This indicates that it is difficult for laboratories to consistently maintain “Acceptable” performance across all targeted analytes in all sample matrices

27. MAPEP – Letters of ConcernNumber of Letters Issued Compared to the Number of Analyses Performed • 86 analytes were targeted for test session 18 • Total analyses performed for consecutive test sessions 17 and 18 were 7030 + 6575 = 13605 analyses • 45 Letters per 13605 analyses indicates about 0.3 % of the analyses performed triggered issuing a Letter of Concern

28. MAPEP Program Challenges • Incorporate contract language to use MAPEP as the vehicle of choice for performance evaluation and testing for laboratories directly/indirectly involved with DOE activities • Improvements in PT tests results • Market program – sell it and see the importance of it • One shot - New remedial PT sample policy/must also pass subsequent PT test session • Revise/update letters of concern • Incorporate MAPEP as a DOE Order requirement

29. Software Development Toolkits Background Visual Sample Planning Improves quality of environmental field/facility sampling strategies while minimizing number of samples needed to meet regulatory requirements

30. Software Development Toolkits Program Challenges • Institutionalize VSP across DOE as facilitator of defensible systemic planning and decision making • Minimize sampling and analysis cost by reducing number of samples/wells required for confident decisions • Ensuring most representative samples are obtained without losing hotspot detection ability (multi-increment sampling) • Improve ability to visualize and communicate DQO-based decision support Website: http://dqo.pnl.gov/vsp

31. Pipeline Ongoing Field Operations Environmental Remediation Decontamination and Decommissioning Assuring Environmental Data Quality Hazardous Waste Treatment/Disposal Management

32. ASP Program Contact Information George Detsis, Analytical Services Program (ASP) Manager Phone: (301) 903-1488 E-mail:  George.Detsis@hq.doe.gov Carolyne Thomas - DOECAP Manager, DOE Oak Ridge Phone: (865) 576-2690 E-mail:  thomascf@oro.doe.gov Guy Marlette, MAPEP Coordinator, Idaho National Laboratory Phone: (208) 526-2532 E-mail: marletgm@id.doe.gov Brent Pulsifer, VSP Coordinator, Pacific Northwest National Laboratory Phone: (509) 375-3989 E-mail: Brent.Pulsipher@pnl.gov

33. Questions