DoD Environmental Data Quality Workgroup Update

1. DoD Environmental Data Quality Workgroup Update Presented to: Joint Services Environmental Management Conference April 2005 Edward Hartzog Director, NAVSEA Laboratory Quality & Accreditation Office Chair, DoD EDQW DoD Representative, IDQTF

2. Topics • Overview • Key Quality Systems Drivers • Policy and Guidance • Quality Systems Implementation • Joint Laboratory Oversight • Perchlorate Sampling and Testing • Training and Outreach

3. Data Quality Issues Affect Mission & Operations • Environmental decisions are based on sampling and testing data • 95% of DoD lab testing is outsourced • Requirements vary at federal, state, local levels • DoD has unique issues (e.g. emerging contaminants, munitions, vessel discharges)

4. DoD Inspector General Audit Report, Feb ‘97Laboratory Support Services for Environmental Testing • Audit Results • “Organizations reviewed were not efficient and effective in the procurement and administration of environmental testing contracts” • Recommendations • Consolidate requirements of environmental tests • Develop standardized quality assurance procedures • Establish adequate procedures to administer contractor performance • Include government remedy clauses in environmental testing contracts

5. EPA Inspector General Report, Sept ‘98Superfund Quality Assurance Program (Regions 1-10) • Audit Results • EPA had developed many critical elements necessary for a strong and effective QA program BUT • Managers had not demonstrated commitment to fully develop and implement the program • Recommendations • Design a strategy to institutionalize QA agency-wide • Improve oversight • Develop minimum QA requirements project planning, oversight, training, tools/resources, authority

6. Overview - EDQW • Established by DUSD(ES) 1996, Navy chair • Members: Army, Navy, Air Force, DLA, OSD • Tasks: • Develop and recommend DoD policy for environmental data quality • Respond to legislative/regulatory initiatives • Represent DoD on Intergovernmental work groups (e.g. IDQTF, NELAC) • Respond to DoD IG recommendations Ensure the generation of environmental data of known and documented quality

7. Overview - EDQW Organization • Principal (voting) representatives • Ed Hartzog – Navy (acting chair) • Rosemary Gaffney – Army (USACHPPM) • Tim Mukoda – Air Force (SAF/IEE) • OSD Liaison – Ed Miller • Technical representatives • Laboratory Oversight, lead – Fred McLean (NAVSEA) • Quality Systems Implementation, lead – Skip Darley (NAVSEA) • Data Review and Management, lead – Dave Koran (HQ – USACE) • Contractor support • Perot Systems Government Services • Versar, Inc.

8. Overview - IDQTF • Established by EPA 1997, Federal Facility Restoration and Reuse Office (FFRRO) lead • Members: OSWER, EPA QA Staff, EPA Regions, DOE, and DoD • Tasks: • Respond to EPA IG reports • Develop written consensus agreements for environmental quality systems • Outline roles and responsibilities for data quality oversight at Federal facilities

9. Key Quality Systems Drivers • DoD Information Quality Guidelines, Ensuring Quality of Information Disseminated to the Public by the Department of Defense • Proposed DoD Instruction 4715.xx, Environmental Data Quality Assurance • Draft DoD Procurement Policy, Implementing Minimum QS Performance Standards into DoD Acquisitions Involving Environmental Sampling and Testing

10. Data Quality ChallengesEnsuring Quality of Information Disseminated to the Public by the Department of Defense, February 2003 Information Quality Utility Information meets the needs of its intended users Integrity Information is protected from unauthorized access or revision Objectivity Information is accurate, clear, complete, unbiased, and reliable Data must be “capable of being substantially reproduced”

11. Proposed DoD Instruction 4715.XXEnvironmental Data Quality Assurance • Assigns responsibilities for implementing environmental quality systems • Implements DoD Data Integrity Policy • Authorizes the publication of key Quality Systems documents • Establishes programs to monitor progress in quality systems implementation Final Draft – December ‘04

12. Quality Systems ImplementationDoD Procurement Policy • Provides minimum performance standards for acquisitions involving environmental sampling and testing • Provides sample language to use in solicitations and contracts • Defines minimum qualifications for contractor quality assurance personnel • Specifies prohibited laboratory practices Final Draft 17 March 2005

13. Quality Systems Policy & Guidance • Uniform Federal Policy for Implementing Environmental Quality Systems (UFP-QS) • Uniform Federal Policy for Quality Assurance Project Plans (UFP-QAPP) • Federal Quality Systems Roles and Responsibilities Guidance (R&R) • DoD Quality Systems Manual for Environmental Laboratories (DoD QSM, V3)

14. UFP-QSFinal Version 1, January 2003 • Requirements and guidelines for documenting and implementing acceptable environmental quality systems (based on ANSI/ASQ E4-2004) • Developed to ensure: • Environmental data are of known and documented quality • Data are suitable for their intended uses • Data collection and technology programs meet stated requirements • Can be used to develop new quality systems or evaluate the adequacy of existing quality systems

15. UFP-QAPPInterim Final, July 2004 • Promotes systematic planning; encourages ‘graded approach’ • Provides instructions and worksheets for preparing project-planning documents • Establishes minimum QA/QC criteria for hazardous waste sites • Streamlines development, review, and approval of project-planning documents

16. DoD Quality Systems Manual for Environmental Laboratories (QSM V3) • Defines DoD requirements for laboratories (based on NELAC standards, which are based on ISO/IEC 17025:1999) • Unifies common elements of Army, Navy, and Air Force QSMs • Provides basis for shared DoD assessments and oversight • Addresses method performance criteria, laboratory ethics & prohibited practices https://www.denix.osd.mil/denix/denix.html

17. Federal Quality Systems R&R GuidanceFinal, July 2004 • EPA HQ: Consistent quality systems implementation throughout EPA and states • EPA Regional offices: Consistent review and approval of QAPPs • Federal Departments/Agencies: Agency-specific quality systems implementation • IDQTF: Outreach and assistance Concurrence expected March 2005

18. Quality Systems Implementation • Laboratory Oversight • Quality Assurance Handbook for Perchlorate Investigations • Training and Outreach

19. Laboratory Oversight‘NELAP Plus’ • NELAP accreditation provides baseline laboratory credentials • DoD resources focused on assessment of conformance to DoD QSM and project-specific requirements • Components of DoD Laboratory Assessment Protocol include: • Assessment checklists based on DoD QSM • Joint assessments • Laboratory assessment database

20. PerchlorateDoD Interim Policy(Sept 2003) • Components must collect and compile perchlorate data for: • Drinking water suppliessubject to Unregulated Contaminant Monitoring Rule (UCMR) • Wastewater dischargespermitted under National Pollutant Discharge Elimination System (NPDES) • Environmental restoration siteswhere release may have occurred and complete human exposure pathway is likely to exist • Range assessmentsconducted under Munitions Action Plan and Defense Planning Guidance

21. Perchlorate:Data Quality Issues • Most existing data based on various modifications of EPA Method 314.0 • Method developed/validated for use in drinking water • Non-specific/subject to interferences • MRL in drinking water = 4 ppb • Not suitable for use in other matrices

22. Perchlorate:DoD Quality Assurance Handbook • Guides preparation of project-planning documents • Guides selection of appropriate methods and qualified laboratories • Implements DoD Quality Systems Policy & Guidance DoD Quality Assurance Handbook for PERCHLORATE Investigations Planning, Implementation, and Assessment Final Draft March 2005

23. DoD Quality Assurance Handbook Perchlorate Sampling and Testing • Laboratories must comply with the DoD QSM • Results above regulatory or action limit must be confirmed using perchlorate-specific technology • Ability to achieve MRL must be demonstrated in matrix of concern • Selected methods must meet specified method performance criteria (MPCs)

24. DoD Quality Assurance Handbook Perchlorate Sampling and Testing Management and Review of Data • Field documentation requirements • Minimum requirements for laboratory data deliverable packages • Internal and third-party data review procedures

25. Quality Systems ImplementationTraining and Outreach • ISEERB-approved training: • Environmental Quality Sampling • Interagency UFP-QAPP Training NAVSEA 04XQ training: A2LA Laboratory Assessors NAVSEA 04XQ outreach: www.navylabs.navy.mil

26. DoD Environmental Monitoring and Data Quality (EM/DQ) WorkshopMyrtle Beach, SC April 4 – 8 • National forum for information exchange • Managing environmental data quality to support DoD mission and operations • Evolving policy, innovative strategies, technical tools • Training • DoD QSM – Understanding and Assessing the ‘Gray Boxes’ • DoD QSM Version 3 - Overview • Technical Implementation of SEDD

27. Sound Science: The Payoff • The right data the first time - means the right decision the first time • Reduced costs for compliance • Streamlined restoration • Reduced liability • Sustained operational readiness • Public confidence

28. Improving Environmental Data Quality… Because the Right Decisions Require Quality Data HartzogEB@navsea.navy.mil (Acting EDQW Chair) www.navylabs.navy.mil www.denix.osd.mil/denix/DOD/Working/EDQW/edqw.html