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 (RR)
• 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

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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
  170251999)
• 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 RR 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 OversightNELAP 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 supplies subject to Unregulated
  Contaminant Monitoring Rule (UCMR)
• Wastewater discharges permitted under National
  Pollutant Discharge Elimination System (NPDES)
• Environmental restoration sites where release may
  have occurred and complete human exposure pathway
  is likely to exist
• Range assessments conducted under Munitions
  Action Plan and Defense Planning Guidance

21
PerchlorateData 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
PerchlorateDoD 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) Workshop Myrtle 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

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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

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Improving Environmental Data Quality Because
the Right Decisions Require Quality Data
HartzogEB_at_navsea.navy.mil (Acting EDQW
Chair) www.navylabs.navy.mil www.denix.osd.mil/de
nix/DOD/Working/EDQW/edqw.html