May 20, 1997
          
          
          
          MEMORANDUM FOR:     THE SECRETARY
          
          FROM:               John C. Layton
                              Inspector General
          
          SUBJECT:            INFORMATION:  Report on "Audit of
                              the Savannah River Site's Quality 
                              Control Program for Groundwater
                              Sampling"
          
          BACKGROUND
          
          The Savannah River Site's groundwater remediation
          program was managed by the Department of Energy's
          (Department) management and operating contractor for
          the site, Westinghouse Savannah River Company
          (Westinghouse).  One component of the remediation
          program was the quality control program.  The goal of
          the groundwater quality control program was to ensure
          that the results of laboratory analyses of groundwater
          samples were accurate and precise so that they could be
          relied upon for making remediation decisions.  The
          objective of this audit was to determine whether
          Westinghouse acquired the minimal number of laboratory
          analyses required to ensure that groundwater sampling
          results met this criteria.
          
          DISCUSSION
          
          Westinghouse required more quality control analyses
          than necessary to ensure that groundwater sampling
          results were accurate and precise.  This occurred
          because Westinghouse originally designed its
          groundwater quality control program to secure
          Departmental acceptance, and it did not periodically
          review program requirements to identify and eliminate
          unnecessary analyses.  As a result, about $500,000 of
          the $859,000 spent on the program in Calendar Year 1995
          was unnecessary.  During the audit, Westinghouse
          discontinued two types of laboratory analyses,
          resulting in annual savings to the Department of about
          $200,000.  While acknowledging Westinghouse's
          accomplishments, we determined that it could save the
          Department an additional $300,000 annually by
          eliminating the requirement for other nonessential
          analyses.
          
          Based on audit results, we recommended that the Manager
          of Savannah River Operations Office:  (1) require
          Westinghouse  to eliminate split sample analyses from
          its groundwater quality control program unless a clear
          requirement can be demonstrated;  (2) require
          Westinghouse to periodically review the effectiveness
          of the groundwater quality control program and modify
          the types and numbers of laboratory analyses required
          based on review results; and, (3) perform a "for cause"
          review of Westinghouse's other quality control programs
          to evaluate the appropriateness of quality control
          analyses being performed.
          
          The Manager, Savannah River Operations Office,
          concurred with the finding and recommendations.
          
          Environmental remediation quality control programs and
          programs for testing and sampling have been the subject
          of numerous recent Office of Inspector General audit
          reports.  In these reports, we raised concerns about
          the Department's implementation of quality control
          programs.  We recognize the importance of quality
          control programs as a means of ensuring that the
          Department's environmental remediation efforts are
          properly focused and that the Department is getting
          value for the resources it applies to testing and
          sampling.  As noted in this report, however, despite
          the importance of quality control programs, the cost of
          such programs should be reasonable and commensurate
          with existing requirements.
          
          Attachment
          
          cc:Deputy Secretary
             Under Secretary
             Manager, Savannah River Operations Office
          
                                
                                
                    U.S. DEPARTMENT OF ENERGY
                   OFFICE OF INSPECTOR GENERAL
                                
                                
                                
                                
                          AUDIT OF THE
                                
          SAVANNAH RIVER SITE'S QUALITY CONTROL PROGRAM
                                
                    FOR GROUNDWATER SAMPLING
                                
                                
                                
                                
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  Report Number:  DOE/IG-405     Eastern Regional Audit Office
  Date of Issue:  May 20, 1997   Oak Ridge, TN  37830
                          
                          
                          AUDIT OF THE
          SAVANNAH RIVER SITE'S QUALITY CONTROL PROGRAM
                    FOR GROUNDWATER SAMPLING
                                
                                
                        TABLE OF CONTENTS
                                
                                
                                                            Page
                                                                 
          SUMMARY . . . . . . . . . . . . . . . . . . . . .  1
 
PART 1  - APPROACH AND OVERVIEW . . . . . . . . . . . . . .  2
 
          Introduction . . . . . . . . . . . . . . . . . . . 2
 
          Scope and Methodology . . . . . . . . . . . . . .  2
 
          Background . . . . . . . . . . . . . . . . . . .   3
 
          Prior Audit Reports . . . . . . . . . . . . . . .  3
 
PART II - FINDING AND RECOMMENDATIONS . . . . . . . . . . .  5
 
          Laboratory Analyses of Quality Control Samples. .  5
 
PART III  -MANAGEMENT AND AUDITOR COMMENTS . . . . . . . .   8
 
 
                    U.S. DEPARTMENT OF ENERGY
                   OFFICE OF INSPECTOR GENERAL
                    OFFICE OF AUDIT SERVICES
                                
                          AUDIT OF THE
          SAVANNAH RIVER SITE'S QUALITY CONTROL PROGRAM
                    FOR GROUNDWATER SAMPLING
                                
                                
Audit Report Number:  DOE/IG-0405
 
 
                             SUMMARY
                                
                                
     The Savannah River Site's (Site) groundwater remediation 
program was managed by the Department of Energy's (Department) 
management and operating contractor for the Site, Westinghouse 
Savannah River Company (Westinghouse).  The goal of the groundwater 
quality control program, a component of the remediation program, 
was to ensure that the results of laboratory analyses of groundwater 
samples were accurate and precise so that they could be relied upon 
for making remediation decisions.  The objective of this audit was 
to determine whether Westinghouse acquired the minimal number of 
laboratory analyses required to ensure that groundwater sampling 
results were sufficiently accurate and precise.
  
     We found that Westinghouse required more quality control analyses
than necessary to ensure that groundwater sampling results were accurate
and precise.  This occurred because Westinghouse originally designed its
groundwater quality control program to secure Departmental acceptance,
and it did not periodically review program requirements to identify and
eliminate unnecessary analyses.  As a result, about $500,000 of the
$859,000 spent on the program in Calendar Year 1995 was unnecessary.
During the audit, Westinghouse discontinued two types of laboratory
analyses, resulting in annual savings to the Department of about
$200,000.  While acknowledging Westinghouses accomplishments, we
determined that the Department could save an additional $300,000 
annually if other nonessential analyses were discontinued.
  
     Management concurred with the finding and recommendations in 
the report.
                                
                                       (Signed)_______
                                       Office of Inspector General
                             
                             
                             PART I
                                
                      APPROACH AND OVERVIEW
                                
                                
INTRODUCTION
  
     One of the primary missions at the Site was the remediation of
contaminated groundwater which was carried out by the Site's manage-
ment and operating contractor, Westinghouse.  Westinghouse obtained
information about the level of contamination in the groundwater from 
the analyses of groundwater samples performed by three subcontractor
laboratories.  In order to make informed remediation decisions,
Westinghouse needed confidence in the accuracy and precision of the
analyses reported by the subcontractor laboratories.  That assurance 
was obtained through Westinghouse's groundwater quality control 
program.  The objective of the audit was to determine whether 
Westinghouse acquired the minimal number of laboratory analyses 
required to ensure that the sampling results were sufficiently 
accurate and precise.
  
  
SCOPE AND METHODOLOGY
  
     The audit was performed at the Site from June 24, 1996, through
December 9, 1996.  To accomplish the audit objective, we:
  
     o Reviewed applicable Federal, State, and Department regulations
       regarding groundwater analysis;
     
     o Evaluated current operating costs for the groundwater sampling
       program;
     
     o Interviewed the Savannah River Operations Office (Savannah 
       River) and Westinghouse project managers assigned to the 
       quality control program for groundwater sampling; and
     
     o Reviewed documentation pertaining to the history and develop-
       ment of the groundwater quality control program.
     
     The audit was conducted in accordance with generally accepted
Government auditing standards for performance audits, and included tests
of internal controls and compliance with laws and regulations to the
extent necessary to satisfy the objective of the audit.  Because our
review was limited, it would not necessarily have disclosed all internal
control deficiencies that may have existed at the time of our audit.  We
relied on computer-generated data during this audit and, thus, tested its
reliability.  Specifically, we used Westinghouses data base containing
the results of groundwater analyses.  We verified the types and numbers
of analyses performed by comparing the data base to another independently
generated record of the analyses.
               
     We held an exit conference with the Deputy Assistant Manager for
Environmental Quality, Savannah River and his staff on March 5, 1997.
Management's comments are summarized in Part III of the report.
  
  
BACKGROUND
  
     For over 40 years, the Site used five nuclear reactors to fulfill
its primary mission of producing tritium and other radioisotopes for 
use in defense-related activities.  In August 1988, the Department 
shut down the last of the Site's three operating reactors.  Sub-
sequently, the Site's primary mission was changed from producing 
nuclear materials to managing waste products generated during weapons 
production and restoring the environment to a level acceptable under 
current laws and regulations.  One of the contaminated areas needing 
environmental remediation was the groundwater under the Site.
  
     In Calendar Year (CY) 1995, Westinghouse spent about $3.2 million 
to have 3 subcontractor laboratories analyze about 69,000 groundwater
samples in support of the remediation mission at the Site.  The
Department needed confidence in the accuracy and precision of that
information in order to make the best remediation decisions possible.  
As a result, a quality control program was established.
  
     To evaluate the accuracy and precision of the laboratories' 
analyses of groundwater samples, Westinghouse required the laboratories 
to analyze quality control samples and report the results back to 
Westinghouse.  In CY 1995, Westinghouse paid the laboratories about 
$859,000 to analyze and report on more than 17,000 groundwater 
quality control samples.
  
     Westinghouse's quality control program confirmed that the three
laboratories' analyses of groundwater samples were sufficiently 
accurate and precise for decision-making purposes.  In addition to 
Westinghouse's program, the laboratories also participated in several 
other quality control programs, including evaluations by other elements 
of the Department, the U.S. Environmental Protection Agency, and the
laboratories' own internal quality control activities.  Therefore,
Westinghouse could be confident about the results of the laboratories'
analyses of groundwater samples.
  
  
PRIOR AUDIT REPORTS
 
     The Office of Inspector General (OIG) previously issued a 
report dealing with groundwater remediation at the Site.  In report 
ER-B-96-02, Audit of Groundwater Remediation Plans at the Savannah 
River Site, dated June 11, 1996, we concluded that the Department 
entered into a remediation agreement with regulatory agencies based 
on unreasonable clean-up standards.  The agreement required that the 
Department remediate groundwater in the F and H Areas to drinking-
water standards.
  
     In addition, the OIG issued several audit reports dealing with
groundwater remediation at other Departmental sites.  In report 
WR-B-97-03, Audit of Groundwater Monitoring at Hanford, dated 
November 15, 1996, we determined that Hanford's contractors dupli-
cated each other's work in sampling and analyzing groundwater and 
in reporting results.  In report DOE/IG-0374, Audit of the Department 
of Energy's Commercial Laboratory Quality Assurance Evaluation Program, 
dated June 20, 1995, we concluded that the Department's contractors 
conducted redundant quality assurance evaluations of some commercial 
laboratories, did not evaluate others, applied standards inconsistently, 
produced inconsistent results, and did not communicate the results 
among contractors.  Finally, in report DOE/IG-0293, Audit of Testing 
Laboratory Support to the Environmental Survey Program, dated 
December 21, 1990, we determined that samples were not always analyzed 
by Departmental laboratories within required time frames and 
laboratories continued to analyze samples after failing performance
evaluation tests.
     
     Our audit disclosed a material internal control weakness that
management should consider when preparing its yearend assurance
memorandum on internal controls.
                             
                             
                             PART II
                                
                   FINDING AND RECOMMENDATIONS
 
                                
Laboratory Analyses of Quality Control Samples
 
FINDING
 
    Departmental regulations require that Westinghouse develop a cost-
effective quality control program, including programs for groundwater
sampling.  Although Westinghouse developed a program that ensured
laboratory analyses of groundwater samples were accurate and precise, 
the program was not cost-effective.  Specifically, Westinghouse required 
more quality control analyses than necessary to ensure the accuracy and
precision of sample results.  This occurred because Westinghouse designed
the program to secure Departmental acceptance and did not periodically
assess program effectiveness.  As a result, about $500,000 of the
$859,000 spent on the program in CY 1995 was unnecessary.  During the
audit, Westinghouse discontinued two types of laboratory analyses,
resulting in annual cost savings of about $200,000.  We determined that
an additional $300,000 could be saved each year if other nonessential
analyses were eliminated.
 
 
RECOMMENDATIONS
 
     We recommend that the Manager, Savannah River Operations Office:
     
          Require Westinghouse to eliminate split-sample analyses 
          from its groundwater quality control program unless a 
          clear requirement can be demonstrated,
     
          Require Westinghouse to periodically review the effective-
          ness of the groundwater quality control program and modify 
          the types and numbers of laboratory analyses required based 
          on review results, and
     
          Perform a "for cause" review of Westinghouse's other quality 
          control programs to evaluate the appropriateness of quality 
          control analyses being performed.
 
        
MANAGEMENT REACTION
 
     Management concurred with the finding and recommendations.  
Comments received from the Manager, Savannah River Operations Office, 
are summarized and addressed in Part III of this report.
 
 
 
 
                       DETAILS OF FINDING
 
 
DEPARTMENTAL REQUIREMENTS
 
     Departmental Order 5700.6C, Quality Assurance, requires management
and operating contractors to develop cost-effective quality control
programs, including programs for groundwater sampling.  Contractors are
required to periodically assess the effectiveness of their programs,
including the types and numbers of analyses required.  The order provides
general guidelines for contractors to follow in developing effective
programs.  However, it does not specify the types or numbers of analyses
required for an effective groundwater quality control program.
 
 
WESTINGHOUSE'S QUALITY CONTROL PROGRAM
 
     Westinghouse's quality control program was not cost-effective.
Westinghouse required more quality control analyses than necessary to
ensure the accuracy and precision of sample results.  During the audit,
Westinghouse performed a partial assessment of its groundwater quality
control program and eliminated requirements for laboratories to perform
(1) gas chromatographic mass spectrometric volatile organic analysis
(VOA) of field-blank samples1 and (2) quality control analyses of 
split2 field-blank samples.  In CY 1995, the laboratories performed 
about 1,000 VOAs of field blanks and about 3,300 quality control 
analyses of split field-blank samples.
  
     While acknowledging Westinghouse's efforts to eliminate un-
necessary quality control analyses, we believe Westinghouse could 
do more.  Specifically, Westinghouse could eliminate quality control 
analyses for all split samples, not just the split field-blank 
samples, without adversely affecting program results.
  
     Split samples added little or no value to Westinghouse's 
groundwater quality control program.  Westinghouse used the analyses 
of split samples to compare the results reported by two laboratories 
for identical samples.  The comparison was unnecessary because 
Westinghouse already had confirmation from other quality control 
tests that the laboratories were sufficiently accurate and precise.  
Further quantification of how the  acceptable results of one 
laboratory compared to the acceptable results of another laboratory 
did not increase the Department's ability to rely on groundwater 
sampling data.
     
     During CY 1995, Westinghouse sent about 9,900 split samples to 
the laboratories for analysis.  As a result of our audit inquiries,
Westinghouse reviewed the analyses of split samples and determined 
that it could eliminate the analyses of about 3,300 split field-blank 
samples.  Westinghouse's determination was based on its observation 
that (1) the  analyses were not required by regulatory agencies, and 
(2) the loss of information about the comparability of laboratories' 
analyses of field-blank samples would have no impact on the quality 
control program for groundwater sampling.  As explained above, we 
believe that Westinghouse could eliminate quality control analyses 
for all split samples, not just the split field-blank samples, without 
adversely affecting the groundwater quality control program.
  
 
PROGRAM DEVELOPMENT AND PERIODIC REVIEW
 
     Westinghouse acquired more laboratory analyses than needed 
because it designed the groundwater quality control program to secure
Departmental acceptance, and it did not periodically review the program
to identify and eliminate unnecessary analyses.  In the absence of
specific guidelines as to the types and numbers of quality control
analyses required by the Department, Westinghouse designed its program 
to be certain that the Department would approve the level of testing
performed.  After the program began, Westinghouse did not periodically
review and modify its requirements as required by Departmental Order
5700.6C.  Although the program began in CY 1991, Westinghouse performed
its first internal assessment of a portion of its quality control 
program during our audit.  That assessment resulted in the elimination 
of some VOAs and quality control analyses of split field-blank samples.
        
COST OF UNNECESSARY QUALITY CONTROL ANALYSES
   
     We determined that about $500,000 of the $859,000 spent on
Westinghouse's quality control program in CY 1995 was unnecessary.
During the audit, Westinghouse eliminated annual requirements for 
about 4,300 analyses, thereby saving the Department about $200,000 
each year.  However, we believe Westinghouse could save the 
Department another $300,000 annually by completely eliminating 
requirements for analyses of split samples.
  
     In addition to procurement costs, reducing the number of 
quality control analyses would reduce other Westinghouse costs, such 
as the cost of preparing and handling unnecessary samples and the cost 
of shipping the samples to the laboratories.  We could not quantify 
these additional savings because Westinghouse's accounting system 
did not separately identify these costs.
  
                            PART III
                                
                 MANAGEMENT AND AUDITOR COMMENTS
 
 
     In responding to the initial draft of this report, the Manager,
Savannah River Operations Office concurred with the finding and
recommendations.  Management's comments are summarized and addressed
below.
 
Recommendation 1.   Require Westinghouse to eliminate split-sampling
analyses from its groundwater quality control program unless a clear
requirement can be demonstrated.
 
     Management Comments.  Concur.  Savannah River Site will follow
external requirements like Environmental Protection Agency (EPA) 
guidance cited in Handbook for Analytical Quality Control in Water 
and Waste-water Laboratories (EPA-600/4-79-019).
 
     Auditor Comments.  Management's proposed actions are
responsive to the recommendation.
 
Recommendation 2. Require Westinghouse to periodically review the
effectiveness of the groundwater quality control program and modify 
the types and numbers of laboratory analyses required based on review
results.
 
     Management Comments.  Concur.  Westinghouse will be directed to 
review and report on the effectiveness of its groundwater quality 
control program for FY 1996 within 120 days from the date of this
report, with subsequent annual reviews and reports for each fiscal 
year by the first of February of the following year.
 
     Auditor Comments.    Management's proposed actions are
responsive to the recommendation.
 
Recommendation 3.   Perform a "for cause" review of Westinghouse's 
other quality control programs to evaluate the appropriateness of 
quality control analyses being performed.
 
     Management Comments.  Concur.  Savannah River will direct
Westinghouse to determine the appropriateness of the quality 
control analyses being performed and to look for cost effective 
approaches in complying with these requirements.
 
     Auditor Comments.   Management's proposed actions are
responsive to the recommendation.
                                               
                                               IG Report No._IG-0405
                                                                    
                                                                    
                                
                                
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_______________________________
1 Field-blank samples were bottles of deionized water that were
transported to the wells, opened and closed at the wells, and sent to
laboratories to be analyzed.  If a field-blank sample was analyzed and
determined to be contaminated, management would suspect that contaminants
were introduced to the groundwater samples during extraction at the site.
2 Split sampling involved physically dividing a single sample into two
samples and sending each sample to a different laboratory for analysis.
Split samples were used to compare the results reported by two
laboratories for identical samples.