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Office of Environment, Health, Safety and Security 1
Debbie Rosano- Director, Office of Sustainable Environmental Stewardship (DOE-AU-21)
Welcome All
Office of Environment, Health, Safety and Security 2
Department of Energy
Analytical Services Program Annual Training Workshop
SeriesJuly 25-August 15, 2020
Steve ClarkManager, Analytical Services ProgramOffice of Sustainable Environmental Stewardship (AU-21)Office of Environment, Health, Safety and SecurityU.S. Department of Energy
Agenda
4Office of Environment, Health, Safety and Security
• Logistics• Training Workshop Objectives• Virtual Workshop Series Agenda • DOE Analytical Services Program Overview • DOE Consolidated Audit Program (DOECAP)• FY 2019 DOECAP Accomplishments• COVID-19 Impacts to Program• New Tools and Adaptation• Audit and Assessment Schedules• ASP Workshops
Logistics
• Please maintain your audio on MUTE • Question and Answer Sessions will follow each session. • Questions can be submitted using the CHAT on your WEBEX
screen. • All presentations will be posted at the end of the series on
the DOECAP Sharepoint (SP) site and the registration page link for those without SP access.
• Restroom breaks are at your leisure • Workshop Questionnaire- Weekly email link to the
workshop questionnaire
Office of Environment, Health, Safety and Security 5
Training Workshop Objectives
• Adapt to COVID-19 Environments
• Increase program awareness and availability to the DOE Complex
• Collaborate with stakeholders on programmatic needs for DOECAP deliverables
• Provide direction and promote suggestions for programmatic improvement in dealing with the “New Normal”
• Provide knowledge of available DOECAP audit tools and programs
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Office of Environment, Health, Safety and Security 7
2020 Department of Energy Analytical Services Program Virtual Training Workshop Series Agenda
Office of Environment, Health, Safety and Security 8
2020 Department of Energy Analytical Services Program Virtual Training Workshop Series Agenda
Office of Environment, Health, Safety and Security 9
2020 Department of Energy Analytical Services Program Virtual Training Workshop Series Agenda
Analytical Services ProgramOverview
Made up of 3 Distinct Services
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The Analytical Services Program (ASP) has traditionally included three components:
• Mixed Analyte Performance Evaluation Program (MAPEP) • Systematic Planning and Data Assessment Tools Program – Visual Sample Plan (VSP)• DOE Consolidated Audit Program (DOECAP)
All components are essential to mission-critical DOE operations, such as ongoing environmental monitoring, environmental remediation, and long-term legacy management and surveillance.
Office of Environment, Health, Safety and Security
ASP
DOECAP TSDF Audits
Visual Sample Plan (VSP)
DOECAP-Accreditation
Program
MAPEP Proficiency
Testing
11
DOE ASP Overview
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DOECAP
12
Commercial Waste Treatment, Storage, and
Disposal Facilities (TSDFs):
Audits conducted by federal and contractor volunteers from throughout DOE Complex
Commercially-Operated Analytical Environmental
Laboratories (DOECAP-AP):
Assessments conducted by 3rd-party accrediting bodies, supported by DOE complex-wide federal and
contractor staff
Photo Courtesy of DOE Staff Photographer, Steve Clark Photo Courtesy of DOE Staff Photographer, Steve Clark
Office of Environment, Health, Safety and Security
Importance of DOECAP Audits
Overall Focus: Reducing Risk and Liability to the Department
Audited/Assessed Facilities are checked on how well they are:
1. Following their established procedures2. Safely managing DOE generated waste at your facility3. Maintaining compliance with applicable local, state, and
federal regulations, permits, etc.4. Providing effective and up-to-date personnel training5. Maintaining DOECAP-AP accreditation (laboratories)
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DOECAP Drivers
• Original Catalyst: Office of Inspector General Report, dated 1995. Supported by a follow-up, dated 2016.
• Laboratories: DOE Order 414.1D, Quality Assurance (QA), establishes DOE’s goal of achieving quality work based on performance and quality improvement, which requires thorough, rigorous assessments and effective corrective actions.
• TSDF: DOE Manual (M) 435.1-1, Radioactive Waste Management Manual, requires DOE field element managers to perform an annual review of commercial treatment, storage, and disposal facilities.
• Contract Language: Many DOE sites include references to DOECAP in their contracts with analytical laboratories and TSDFs (specific language used varies widely).
14Office of Environment, Health, Safety and Security
Value and Uses of the DOECAP Audit Report
• TSDF Audit Reports are used by: • Field Element Managers (FEMs): Supports DOE M 435.1-1 annual acceptability
reviews• Site Prime contractors:
• Supports QA oversight requirements• Acceptance criteria for their approved supplier list for TSDFs
• Commercial Laboratories: Required to audit TSDFs that accept their low-level radioactive wastes
• Federal Site Managers: Referenced in preparing National Environmental Policy Act-Categorical Exclusion annual reviews/approvals for sending waste to commercial TSDF facilities
• State Regulator- Reports are often referenced• Laboratory Accreditation/Audit Reports:
• Satisfies DOE QA oversight requirements and/or Quality Assurance Plan• Support laboratories ability to produce defensible data for site specific decisions
15Office of Environment, Health, Safety and Security
Value and Uses of the DOECAP Audit Report (Continued)
TSDF & Laboratory Interactions
• TSDF’s use DOE accredited laboratories
• Laboratories ship sample waste to TSDF’s
• Many laboratories rely on DOECAP TSDF audit reports to support requirements in the DoD/DOE Quality Systems Manual
Office of Environment, Health, Safety and Security 16
TSDF
DOECAP Reports
DOE Accredited
Lab
DOECAP Laboratory Accreditation Program (DOECAP-AP)
• Memorandum identifying the change to 3rd party accreditation for commercial analytical laboratories -August 29, 2017
• Began 3rd Party Accreditation Assessments in FY 2018
• DOECAP-AP is in its third successful year of implementation with 24 participating laboratories
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18
Fiscal Year 2019 DOECAP Audits/Assessments Supported:
29 DOE Sites
$53 Million in DOE Contracts 309 Total Contracts
Office of Environment, Health, Safety and Security
DOE Support by Fiscal Year
Fiscal Year 2020 DOECAP Audits/Assessments Supported:
29 DOE Sites
$63 Million in DOE Contracts 288 Total Contracts
DOECAP-AP Participants:Laboratories Calendar Year 2019
DOECAP-AP Participating LaboratoriesALS Laboratory GroupFort Collins, Colorado
ALS Laboratory GroupCincinnati, Ohio
ALS Laboratory Group Salt Lake City, Utah
ARS Aleut Analytical, LLCPort Allen, Louisiana
BC Laboratories, Inc. Bakersfield, California
Brooks Rand Labs, LLCSeattle, Washington
Columbia Basin Analytical LaboratoriesPasco, Washington
Eberline Analytical Corporation Oak Ridge, Tennessee
GEL Laboratories, LLC Charleston, South Carolina
Materials and Chemistry Laboratory, Inc. Oak Ridge, Tennessee
Agriculture & Priority Pollutants Laboratories, Inc.Clovis, California
Pace Analytical - South Carolina (formerly SES)West Columbia, South Carolina
Southwest Research Institute San Antonio, Texas
Eurofins TestAmerica, Inc. Arvada, Colorado
Eurofins TestAmerica, Inc. Earth City, Missouri
Eurofins TestAmerica, Inc. Knoxville, Tennessee
EMSL Analytical, IncOak Ridge, Tennessee
Eurofins TestAmerica, Inc.West Sacramento, California
Eurofins Frontier Global Science, Inc.Tacoma, Washington
Brooks Applied LabsBothell, Washington
Pace Analytical LaboratoriesNashville, Tennessee
19Office of Environment, Health, Safety and Security
DOECAP-AP Participants:TSDF Calendar Year 2019
Audited TSDFs
Diversified Scientific Services, Inc. Kingston, Tennessee
Clean Harbors Deer Park, LLCLa Porte, Texas (Nonradiological)
EnergySolutions, LLCOak Ridge, Tennessee
EnergySolutions, LLCClive, Utah
Perma-Fix of Florida, Inc.Gainesville, Florida
UniTech, IncOak Ridge, Tennessee
Waste Control Specialists LLCAndrews, Texas
Perma-Fix Northwest, Inc.Richland, Washington
20Office of Environment, Health, Safety and Security
DOECAP Facilities into 2020
DOECAP-AP Participating LaboratoriesEnthalpy Analytical (Curtis & Tompkins Laboratories)
Berkeley, CaliforniaTestAmerica, Inc. - Richland
Richland, Washington
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Discontinued Laboratories Calendar Year 2019
DOECAP-AP Participating LaboratoriesEnergy Northwest Precision Labs
Richland, WashingtonTorrent Laboratories
Milpitas, California
Applying Laboratories Calendar Year 2020
DOECAP-AP Participating LaboratoriesUS Ecology Nevada
Beatty, NevadaClean Harbors La Porte LLC
La Porte, Texas
US Ecology IdahoGrand View, Idaho
Veolia AlaronAlaron, Pennsylvania
Additional TSDFs Proposed for Calendar Year 2021
DOECAP-AP Participating LaboratoriesVeolia Henderson
Henderson, ColoradoPerma-Fix Environmental Waste Operations Center
Oak Ridge, Tennessee
Clean Harbors Aragonite, LLCSalt Lake City, Utah
Additional TSDF Audit Sites for Calendar Year 2020
22Office of Environment, Health, Safety and Security
Fiscal Year 2019 DOECAP Accomplishments
• 8 TSDF Audits Completed• 23 Laboratory Assessments Completed (CY19)• Reduced Administrative Costs by 25%• Coordinated QSM Development for QSM V6.0• Developed the first draft of the TSDF Program Plan• Provided Support to 292 DOE contracts totaling over $53 Million
Let’s Discuss the “Elephant in the Room”
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Office of Environment, Health, Safety and Security 24
COVID-19 Status
• Return to Work Status for DOE Complex• Varies by region-state-site. Site status
changes based on local conditions, not just at PSO discretion
• Washington, D.C. Capital Region• Phase 2 started June 29th
• Travel Policy for mission critical travel only - Travel limitations during Phase 2 do not permit conferences or DOECAP audits
• No Conference travel or potential on-site audits until Phase 3
Photo courtesy of Steve Clark, DOE Staff Photographer
Office of Environment, Health, Safety and Security 25
COVID-19 Change
DOE MUST Adapt to COVID-19
• Communication - Even More Critical Now
• Opportunity - Advance Using Available Technology and Expertise
• Viability in meeting our Program and Mission Goals
• Implementation Strategies - How Do We Make Change Happen Successfully
• Dedication to Deliver Quality Products and Programs for all our DOE Stakeholders
New Tools and Adaptation
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New Tools and Adaptation (Continued)
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Includes: • Program Details• Stakeholder Roles and Responsibilities• Program Procedures• Checklist Lines of Inquiry (LOI)• LOI Narratives• (Citation) References• Site Description Sheets• Site Information Sheets• Auditor Requirements• And more….
New Tools and Adaptation (Continued)
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Includes: • Program Details• Stakeholder Roles and Responsibilities• Program Procedures• Accrediting Body Conditions and Criteria• Data Quality Work Group Duties• And more….
New Tools and Adaptation (Continued)
Office of Environment, Health, Safety and Security 29
Memorandum Issued June 12:• Acknowledged COVID-19
Impact• Provided Update on how
Accrediting Bodies are addressing their program assessments of laboratories
• Established the DOECAP Remote Audit Procedure for Treatment, Storage, and Disposal Facilities
TSDF Remote Audit Procedure
Office of Environment, Health, Safety and Security 30
Describes all pre-audit preparations and audit conduct necessary to ensure a successful remote audit of contracted waste facilities that perform work under Department-funded contracts related to the treatment, storage, and disposal of DOE generated waste.
NOTE: Remote audits do not replace the quality or level of review necessary for proper oversight of a contractor’s performance. Remote audits are intended as an alternative to the on-site audit when it is not feasible to be onsite, such as during a pandemic.
Remote Audit Tools(Tools YOU Helped Develop)
• Site Description Sheets• Site Information Sheets• Online Checklists w/ Site Specific Checklist
Identifiers• All Online Electronic Format for checklists and
generating reports, including CAPs• Sharepoint Folder for upload of documents
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TSDF Audit Report SiteOnline Checklists
• Easy access - username and password• Easy checklist sorting and answering• Allows Auditor to complete each checklist online
allowing the site to view responses for each line of inquiry
• Export to excel or print in pdf directly for the site • Site can download completed checklists• Only need to update changes for future audits as
changes are identified by the site
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2020 TSDF Remote Audits Schedule
Facility 2020 Remote Audit Date
Veolia-Henderson- CO July 27-28
Waste Control Specialists LLC- TX August 18-19
Perma-Fix, Northwest Inc.- WA August 18-19
Clean Harbors Aragonite, LLC- UT August 25-26
EnergySolutions, LLC –Utah September 10-11
EnergySolutions, LLC- TN September15-16
Diversified Scientific Services Inc.- TN September 28-29
UniTech-BSFR- TN September 29-30
Perma-Fix Florida-FL TBD- prior to October 1, 2020
Office of Environment, Health, Safety and Security 33
DOECAP-AP Assessments Calendar Year 2020Currently Scheduled
Laboratory Dates Type AccreditingBody
ARS International, LLC Aug 10-12 Aug 24-26
(Remote)(Onsite)
ANAB
Pace Analytical – SC Sep 9-11 (Onsite) ANAB
Materials and Chemistry Lab
Aug 26-28 (Remote) PJLA
Brooks Applied Labs Aug 10-12 (Remote) ANAB
RJ Lee Group-CBAL Oct 5-9 (Onsite) A2LA
Office of Environment, Health, Safety and Security 34
2019 Analytical Service Program Training Workshop
35
Total Attendance
121
Accrediting Bodies Represented
3 A2LA PJLAANAB
Labs Represented
14 ALS Fort Collins American Aleut AnalyticalAPPL, Inc. BC Laboratories, Inc.Brooks Applied LabsBureau Veritas Laboratories (Ontario, Canada)Earth Toxics, Inc.Eberline AnalyticalEcoChem, Inc.Eurofins Frontier Global SciencesEurofins Test America Denver, CO
Eurofins Test America Milton, WIEurofins Test America Pittsburgh, PAEurofins Test America St. Louis, MOEurofins Test America West Sacramento, CAGEL Laboratories LLC Materials and Chemistry Laboratories, Inc.Pace AnalyticalRJ Lee Group, Inc.Shealy Environmental ServicesSouthwest Research Institute
TSDFs Represented
5 EnergySolutions, LLCPerma-Fix CorporateClean Harbors
Waste Control Specialists LLCUnitech Services Group
Other Agencies
4 NavyArmy
Army Corps of EngineersOSHA
Office of Environment, Health, Safety and Security
Key Annual ASP Training Workshop Feedback from Last Year
36
Is DOECAP moving in a positive direction?2018 response : Yes – 92.19%No – 7.81%
Office of Environment, Health, Safety and Security
NEXT YEAR ASP Training Workshop Consideration
• May or September• Omaha, Nebraska• QSM v6.0 Training• TSDF Program
Implementation• PFAS Updates
Office of Environment, Health, Safety and Security 37
Photos Courtesy of Omaha.com
Planning Disclaimer
Office of Environment, Health, Safety and Security 38
Questions?
39Office of Environment, Health, Safety and Security
Contact Information
Steve ClarkAnalytical Services Program Manager Office of Sustainable Environmental Stewardship (AU-21)Office of Environment, Health, Safety and SecurityU.S. Department of Energy, Headquarters (Germantown) steve.clark@hq.doe.gov301.903.1488 (office)540.273.8574 (cell)
40Office of Environment, Health, Safety and Security
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