1. Corporate Overview Analytical Services Program (ASP) George E. Detsis Manager, Analytical Services Program Office of Environment, Health, Safety and Security Office of Sustainability Support 2014 ASP Workshop Albuquerque, New Mexico September 15-18, 2014 1

2. Topics ASP accomplishments Commonalities between audit findings Lessons learned Future considerations 2

3. ASP Accomplishments Implemented Department of Defense (DoD)/DOE Consolidated Quality Systems Manual (QSM) for Environmental Laboratories, and updated the Lab Audit Checklists 20 Lab Audits, which includes 1 Lab Surveillance and 4 Lab Closure Audits 8 Treatment, Storage, and Disposal Facility Audits Processed Corrective Action Plans Maintained a cadre of 134 trained volunteer auditors 3

4. ASP Accomplishments (cont.) DOECAP TSDF Checklist Pilot – The facility completed the audit checklists in advance and self-identified deficiencies (treated DOECAP “SI” as observations rather than audit findings) Updated the TSDF checklists to cover new and revised regulations Initiated a DOE Technical Standard on Lab Proficiency Testing (PT) Engaged DOE managers – Briefings Analytical Services Program – FY 2013 Report 4

5. Making a Difference Lab/TSDF’s Performance Improvements Guard against Complacency Audit report quality improvements – findings are tied to requirements, specific requirements are cited, and the supporting evidence identified by the auditors is explained DoD/DOE QSM provides Labs with one-stop shopping for quality system requirements Reduction/elimination of aged legacy waste 5

6. Laboratory Audits 6

7. Distribution of FY 2014 Laboratory Findings 7

8. Commonalities Between the FY 2014 Lab Findings 8 Using procedures that do not accurately reflect the current laboratory practices. Failing to develop and implement procedures for all applicable requirements. For example: ―Some laboratories have not defined (documented) their practices for receiving samples that potentially contain beryllium, beryllium oxide, and asbestos. Opening incoming sample shipments outside of a ventilation hood, which means that personnel are potentially being exposed to hazardous materials.

9. Commonalities Between the FY 2014 Lab Findings (cont.) 9 Failing to ensure that personnel receive the required training, and/or failing to appropriately document the training taken. Performing calculations associated with sample analysis using spreadsheets with formula cells that are not write- protected. Using acceptance criteria for analytical balances and pipettes that do not meet the QSM requirements.

10. Tentative Laboratory Audit Schedule for FY 2015 LaboratoryMonth & Year TestAmerica, Inc., Knoxville, TNNovember 2014 Eberline Analytical Corporation, Oak Ridge, TNDecember 2014 ALS Laboratory Group, Cincinnati, OHJanuary 2015 Materials and Chemistry Laboratory, Inc., Oak Ridge, TN January 2015 Shealy Environmental Services, Inc., West Columbia, SC February 2015 ALS Laboratory Group, Salt Lake City, UTFebruary 2015 American Radiation Services, Inc., Port Allen, LAMarch 2015 TestAmerica, Inc., Arvada, COMarch 2015

11. Tentative Laboratory Audit Schedule for FY 2015 (cont.) LaboratoryMonth & Year Southwest Research Institute, San Antonio, TXMarch 2015 GEL Laboratories, LLC, Charleston, SCApril 2015 ALS Environmental Group, Fort Collins, COMay 2015 Shealy Consulting, LLC, Lexington, SCMay 2015 TestAmerica, Inc., Earth City, MOMay 2015 TestAmerica, Inc., Richland, WAJune 2015 BC Laboratories, Inc., Bakersfield, CAJune 2015 Brooks Rand Labs, LLC, Seattle, WAJune 2015

12. Accutest, San Jose, CA Alpha Analytical, Ukiah, CA Eurofins Eaton Analytical, Inc., South Bend, IN Microseeps, Inc., Pittsburgh, PA Pace Analytical Services, Lenexa, KS TestAmerica, Inc. West Sacramento, CA TestAmerica, Inc., University Park, IL 9/12/2013, kb 12 “Parking Lot” for Possible Lab Audits in FY 2015 Laboratories Where Combined DOE/NNSA Users Plan to Spend +$50,000 NOTE: Brooks Rand Labs, LLC, was selected from last year’s Lab Parking Lot to become a new DOECAP-audited lab.

13. DOECAP TSDF Audits 13

14. Distribution of FY 2014 TSDF Findings 14

15. Commonalities Between the FY 2014 TSDF Audit Findings 15 Outbound shipping paperwork does not meet the requirements; for example: ―Technical Name requirements for hazardous material shipments ―Shipping Description and Hazard Class for hazardous material shipments ―Required content and signatures on outbound shipping papers Not ensuring that workers complete the required training for work under the hazardous waste management permit and/or failing to properly document completion of the required training.

16. Commonalities Between the FY 2014 TSDF Audit Findings (cont.) 16 Not meeting the requirements for: ―Chemical storage (incompatibles) ―Waste segregation ―Universal waste labeling and marking Failing to properly label measuring and test equipment with the calibration status.

17. TSDFMonth & Year Clean Harbors Colfax, LLC, Colfax, LANovember 2014 Clean Harbors Environmental Services – Deer Park, LaPorte, TX December 2014 Diversified Scientific Services, Inc., Kingston, TNJanuary 2015 EnergySolutions, LLC, Oak Ridge, TNFebruary 2015 Materials and Energy Corporation, Oak Ridge, TN March 2015 Perma-Fix Northwest, Inc., Richland, WAApril 2015 EnergySolutions, LLC, Clive, UTApril 2015 Perma-Fix of Florida, Inc., Gainesville, FLMay 2015 Waste Control Specialists LLC, Andrews, TXMay 2015 9/12/2013, kb 17 Tentative TSDF Audit Schedule for FY 2015

18. 9/12/2013, kb 18 “Parking Lot” for Possible TSDF Audits in FY 2015 Clean Harbors Environmental Services, Buttonwillow, CA Clean Harbors Environmental Services, Grassy Mountain, UT Clean Harbors Environmental Services, Kimball, NE Clean Harbors Environmental Services, Reidsville, NC Stericycle, Inc., Tacoma, WA, and Kent, WA Tradebe Environmental Services, LLC, East Chicago, IN (Headquarters) Veolia Environmental Services Technical Solutions, LLC, Henderson, CO Veolia Environmental Services Technical Solutions, LLC, Menomonee Falls, WI Veolia Environmental Services Technical Solutions, LLC, Phoenix, AZ TSDFs Where Combined DOE/NNSA Users Plan to Spend +$50,000

19. DOECAP Lessons Learned Inconsistent DOE contract language for closed lab’s disposition of analytical samples/waste (disposition timetable) Consequences for FY 2014 DOE on-site lab closures – Taxpayer cost savings – DOE will be farming that work out to other commercial labs Improve “timeliness” of final audit reports 19

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21. Mixed Analyte Performance Evaluation Program (MAPEP) Accomplishments 130 Labs Participate ― 88 domestic and 42 foreign Semiannual PT evaluations: ―MAPEP Series 30: Shipped March 2014 ―MAPEP Series 31: Shipped August 2014 (reporting deadline November 5,2014) Interim remedial PTs 21

22. MAPEP Accomplishments (cont.) Initiated DOE Technical Standard on PT Performed special studies for uranium and strontium International collaborations – building lasting partnerships through science, not weapons 22

23. Participation in MAPEP Improves Performance 23 Laboratories’ performance for analysis of iodine ‑ 129 in water

24. DOE Senior Management Support for MAPEP DOE Chief Health, Safety, and Security Officer memo on December 30, 2013, to program line and field element managers recommends that all onsite and sub- contracted environmental laboratories performing radiological, inorganic, or organic analyses for DOE be encouraged to participate in MAPEP. 24

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26. Visual Sample Plan (VSP) Accomplishments VSP 7.0 Release and complete update of the User’s Manual Discovery Sampling Stratified Sampling Map Tile Servers Spatial Contours Coordinate System Matchup 26

27. VSP Accomplishments (cont.) Lots of enhancements/improvements: ―HTML Help files on the web ―“Save As” previous version ―Sampling heights for walls ―Calibrate maps by scale legend ―Transparency of rooms/kriging/maps ―Labeling sample areas ―Custom color scales 27

28. VSP FY 2014 Training 28 Course outlines are available on the VSP website at: http://vsp.pnnl.gov/training/ current_training.aspx

29. Laboratory Audit Programs – Overall Objective The overall objective is to provide data of known, documented quality to field managers for use in making environmental management and cleanup decisions. Both DOE and DoD have programs that foster this objective, although the agencies go about oversight responsibilities in different ways. 29

30. Future Considerations DOECAP Auditing Activities: – New labs being considered – New nonradiological TSDFs being considered Budget Considerations – FY 2015 budget remains flat 30

31. Future Considerations (cont.) Continuing TSDF Pilot Study of Self – Identified findings/completed checklists More focused DOECAP audit scopes: – Laboratory Audit Disciplines Quality assurance Data quality for organic, inorganic, and radiochemistry analyses – TSDF Audit Disciplines Quality assurance Environmental compliance and permitting Waste operations 31

32. Conclusion Flexibility Dealing with a changing environment/ diminishing budgets Maintaining excellence and consistency while continuing to provide value-added stakeholder benefits, including risk reductions and performance improvements 32

33. Questions? 6/9/201533