U.S. Department of Energy’s Consolidated Audit Program

1. U.S. Department of Energy’sConsolidated Audit Program George E. DetsisManager, Analytical Services ProgramOffice of Corporate Safety Programs, HS-31 Presented before the 2008 Second Annual RadWaste Summit September 2-5, 2008 Las Vegas, Nevada

2. Presentation Outline • Program Overview • Background (IG/GAO) • Checklists • Common Findings • Accomplishments/Challenges

3. Overview of Analytical Services Program

4. Finding from DOE’s Office of the Inspector General and GAO Reports Report on the Audit of DOE’s Commercial Laboratory Quality Assurance Evaluation Program (June 1995) IG and GAO Identified reductions in DOE Auditing and Contracting of Analytical Services • 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. DOECAP Background Purpose: • Reduction audit redundancies • Standardize audit methodology, policies and procedures • Communicate Lessons Learned • Reduce overall Department risks/liabilities • Contractual agreement linkage • Involves all DOE line organizations/field operations • Auditor participants primarily DOE contractor holders • Auditor qualifications/training requirements • Federal staff lead TSDF audits

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

7. 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

8. Audit Checklists Module 1 – Quality Assurance Management Systems Module 2 – Sampling and Analytical Data Quality Module 3 – Waste Operations Module 4 – Environmental Compliance and Permitting Module 5 – Radiological Control Module 6 – Industrial & Chemical Safety Module 7 – Transportation Management

9. Audit Driver • DOE Order 435.1 (manual), Radioactive Waste Management • Requires that DOE first utilize DOE facilities to manage radioactive waste • However, if DOE chooses to use a non-DOE waste vendor, DOE must perform an annual ES&H review

10. Perspective/Context All 7 TSDFs were found to maintain the established management systems and operational activities necessary to meet DOE requirements for the storage, handling, transportation, processing and final disposition of DOE waste.

11. Percent Distribution of FY 2008 TSDF Findings

12. Percent Distribution of FY 2008 TSDF Observations

13. TSDFs Audited in FY08 • Diversified Scientific Services, Inc. (DSSI), Kingston, TN • Energy Solutions, LLC, Oak Ridge, TN • Energy Solutions of Utah, Clive, Utah • Materials and Energy Corporation, Oak Ridge, TN • Perma-Fix Northwest, Richland, WA • Perma-Fix of Florida, Gainesville, FL • Waste Control Specialists, Andrews, TX

14. Common TSDF Findings by Audit Discipline (FY 08) • Quality Assurance Management Systems: • Follow-up on corrective actions • SOP reviews are not current • Training records are not complete • Document control is inadequate • Sampling and Analytical Data Quality: • Waste Analysis Plan Discrepancies • Incomplete SOPs • Waste Operations: • Excessive quantities of aged waste on site • Actual work practice not consistent with SOP or Plan

15. Common TSDF Findings by Audit Discipline (FY 08) cont’d • Environmental Compliance/Permitting: • Container label, designation or storage condition inadequate • Shipment receipt verification incomplete • Area inspections and documentation inadequate • Performing a waste size reduction process without having regulatory approval (one instance) • Radiological Control: • Radiological work permit briefing and training inadequate • Inappropriate monitoring instruments for alpha • Visitor monitoring and training inadequate • Inadequate posting or signage

16. Common TSDF Findings by Audit Discipline (FY 08) cont’d • Industrial and Chemical Safety: • Inadequate Health and Safety Plans or delinquent reviews • Postings for confined space incomplete • Incompatible chemical storage • Inadequate chemical labeling • Transportation Management:   • Lack of training • Records Management not included for all documents • Evaluation of sub-tier contractor incomplete • Incomplete shipping/receiving documentation

17. TSDF Accomplishments • Completed 7 TSDF audits; 1 on-site scoping of non-radiological TSDF • Approved 7 TSDF Corrective Action Plans • Tracked 86% of FY2007 Corrective Actions to completion (57 FY2007 findings closed out of 66 identified) • Updated all Program audit checklists • Increased number of qualified auditors and lead auditors • Continued interagency partnering with EPA, State Agencies, and DoD

18. DOECAP Challenges • Increase Federal team leaders • Increase auditor pool • Radiological control • Industrial and chemical safety • Improve POCs active participation -- HQ/field • Improve localized/regional auditor participation to reduce travel costs • Improve program ownership/responsibility • Increase incorporation of DOECAP language into contracts

19. ASP Program Contact Information George Detsis, Analytical Services Program (ASP) Manager Phone: (301) 903-1488E-mail:  George.Detsis@hq.doe.gov Carolyne Thomas - DOECAP Manager, DOE Oak Ridge Phone: (865) 576-2690E-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