Office of Environment, Health, Safety and Security 1

Debbie Rosano- Director, Office of Sustainable Environmental Stewardship (DOE-AU-21)

Welcome All

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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

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• 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

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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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2020 Department of Energy Analytical Services Program Virtual Training Workshop Series Agenda

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2020 Department of Energy Analytical Services Program Virtual Training Workshop Series Agenda

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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.

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ASP

DOECAP TSDF Audits

Visual Sample Plan (VSP)

DOECAP-Accreditation

Program

MAPEP Proficiency

Testing

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DOE ASP Overview

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DOECAP

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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

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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).

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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

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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

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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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Fiscal Year 2019 DOECAP Audits/Assessments Supported:

29 DOE Sites

$53 Million in DOE Contracts 309 Total Contracts

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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

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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

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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

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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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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

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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)

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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

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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

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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

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2019 Analytical Service Program Training Workshop

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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

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Key Annual ASP Training Workshop Feedback from Last Year

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Is DOECAP moving in a positive direction?2018 response : Yes – 92.19%No – 7.81%

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NEXT YEAR ASP Training Workshop Consideration

• May or September• Omaha, Nebraska• QSM v6.0 Training• TSDF Program

Implementation• PFAS Updates

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Photos Courtesy of Omaha.com

Planning Disclaimer

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Questions?

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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)

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