EPA Inspector General Audit Report:
Region 9 Superfund DQO's, Sept 1998

Summary:

The purpose of the audit was to determine if Region 9 had sufficient procedures in place to ensure that environmental data was of known and acceptable quality for Superfund removal actions. The audit of five removal actions showed Region 9 did not have sufficient procedures over Superfund removal actions to ensure that environmental data was of known and acceptable quality. Also, the Region did not fully use EPA's scientific planning process, called data quality objectives, to ensure its removal actions and corresponding data collection activities were effective and efficient. This audit is also part of a national audit of field sampling. Accordingly, the results of this audit will also be included in a national audit report, to be issued in 1998.

Viewing the Report:

EPA Office of the Inspector General HQs has this audit report on the web. Here is the pdf of the report complete with pictures. It can be read with Adobe Acrobat Reader. (See attached file: 8100223.pdf)

The report (as well as other EPA IG Audit reports) can also be viewed on the EPA IG Web Site: http://www.epa.gov/oigearth/list998.htm

Hanford DQO Approach is recommended

See Chapter 2 on DQOs; note the recommendation to the EPA Regional Administrator to use/adopt the Hanford (Environmental Restoration Contractor [ERC]) methodology for implementing the 7-Step DQO Process, including attaching the ERC DQO Implementation Process Flow Chart as APPENDIX F: Hanford's "Best Practice" for Data Quality Objectives in the report.

Excerpts From the report:

1. Page 29: Underlying Principles of DQOs
   • All collected data have error.
   • Nobody can afford absolute certainty.
   • The DQO process defines tolerable error rates.
   • Absent DQOs, decisions are uninformed.
   
   
2. Page 29: The DQO process is a systematic, scientific method to establish data quality criteria and performance specifications for decision making. The DQO process was developed by EPA to:
   • Help define specific questions that an environmental project is intended to answer;
     
   • Identify the decisions that will be made when using the resulting data;
     
   • Define the allowable risk of decision errors in specific and quantifiable terms; and,
     
   • Optimize the design of data collection.
     

   The DQO process provides two primary benefits:

   1. Better decisions, because they are based on the scientific method and decision error is
      reduced.
      
   2. More cost effective data collection efforts, because managers focus on the quantity and
      quality of data needed for decisions.

3. Page 31: Why DQOs Were Not Used
   • DQOs were not considered mandatory.
   • Lack of DQO training and experience.
   • Perception that DQOs were not practical.
   • Process to support DQOs not in place.
   
   
4. Page 33: Changes Needed to Support DQO Process
   • Require DQOs
   • Set training requirements
   • Use a team approach
   • Designate facilitators
   
   
5. Page 33: BEST PRACTICES

   The U.S. Department of Energy seems to have been particularly successful implementing the DQO process. It should be noted that Energy has required the use of the DQO process at its environmental projects and operations. The Department of Energy sponsors a DQO Internet "web" site that explains the DQO process, provides case studies of lessons learned and cost savings, and identifies DQO resources. The address is http://dqo.pnl.gov/. Our audit of Laboratory Data Quality at Federal Facility Superfund Sites, issued in March 1997, found that the Hanford Nuclear Reservation had developed an effective DQO implementation procedure. This procedure, shown at Appendix F, involves key decision makers in the development of objectives. The Region should consider implementing many aspects of this procedure. A key part of Hanford's DQO process was the use of a facilitator. The facilitator can assist by fostering communication among planning team members and adding objectivity to the decision making process. The facilitator should have a broad range of technical and regulatory expertise and experience in making focused decisions.

6. Page 34: RECOMMENDATIONS

We recommend that the Regional Administrator:

• Require on-scene coordinators to develop DQOs for all removal actions.
• Establish a minimum mandatory training requirement for DQOs for all regional personnel whose duties involve the collection, evaluation, or use of environmental data.
• Require on-scene coordinators to attend DQO training.
• Use a graded or pro-forma approach to develop DQOs depending upon the scope and complexity of the project.
• Use a team approach to develop DQOs. The team should include QA specialists, samplers, chemists, project managers, risk assessors, toxicologists, data users and statisticians.
• Designate a DQO facilitator to assist and coordinate team members through the DQO process.

For more information on the DQO Implementation Process contact:

Sebastian Tindall
QE3C
PO Box 1389
Richland, WA 99352
(509) 845-7078
qe3c@owt.com
http://www.hanford.gov/dqo

For more information the audit report, call:

Katherine Thompson
Auditor in Charge
U.S. EPA Office of the Inspector General
Sacramento, CA
(916) 498-6535

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DQO Coordinator, Sebastian Tindall, (509) 845-7078.

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