Programmatic Synergy in Obtaining Programmatic Synergy in Obtaining Cost Effective Data of Known and Cost Effective Data of Known and

Documented Quality Documented Quality Experiences under the Great Lakes Legacy ActExperiences under the Great Lakes Legacy Act

Louis Blume and Alie MuneerLouis Blume and Alie Muneer

U.S. EPA Great Lakes National Program OfficeU.S. EPA Great Lakes National Program Office

Judy Schofield and Neal Jannelle, CSCJudy Schofield and Neal Jannelle, CSC

EPA Quality Management ConferenceEPA Quality Management Conference

May 14, 2009May 14, 2009

Workshop Overview

Programmatic Synergy in Obtaining Cost Programmatic Synergy in Obtaining Cost Effective Data of Known and Documented Effective Data of Known and Documented QualityQuality

1. Louis Blume, US EPA GLNPO– Experiences under the Great Lakes Legacy Act

2. Linda M. Mauel, US EPA Region 2– Region 2 Support for the GLNPO Braddock Bay Project

3. Bob Avery, The Laboratory of the Michigan Department of Environmental Quality– Challenges of meeting EPA data reporting requirements

4. Michael Johnson, US EPA OSWER– Cool Tools for Cost Effective Data Management

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Presentation Overview

• Background on Great Lakes Legacy Act (GLLA)• Challenges in managing data and meeting

quality system goals under the GLLA• Data Management procedures under the GLLA• GLLA cost comparisons (I wish!)• Recommendations

The data management challenges that GLNPO is facing are similar to those that the Agency will face in the event of a national emergency. 3

GLLA Background

• “Great Lakes and Lake Champlain Act of 2002” passed by Congress on November 12, 2002

• Signed into law by President Bush on November 27, 2002 (Public Law No: 107-303)

• The Great Lakes Legacy Act (GLLA) authorizes $50M per year for contaminated sediment projects in the Great Lakes

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GLLA Background

• Appropriations received to date have been:– FY2004 $10 Million – FY2005 $22 Million– FY2006 $29 Million– FY2007 $30 Million– FY2008/2009 $35 Million– President’s Budget Request for FY2010:

$43M5

GLLA Background

• Currently 42 Areas of Concern (AOCs) throughout the Great Lakes

• Contaminated sediments can be found at many of these AOCs resulting in various beneficial use impairments

• Since 1997, approximately 46* million cubic yards of contaminated sediments have been remediated in the Great Lakes AOCs

6*Secondary QAPP exists, GPRA reportable

The newly reauthorized GLLA

GLLA Reauthorization (2009-2010)• Level authorization $50 M/year• Allows for habitat restoration in

conjunction with remediation • Identify PRPs connected with the site• Site characterization at 100% federal

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Must be in U.S. Areas of Concern (AOCs) and:

1) Implement a plan to remediate contaminated sediment (highest priority)

2) Monitor or evaluate contaminated sediment

3) Prevent further or renewed sediment contamination

GLLA Project Types

All projects require minimum 35% non-All projects require minimum 35% non-Federal matchFederal match

Cost-sharing with non-Federal Sponsor (NFS)

• Non-Federal Cost Share Must be at Least 35% of Total Project Costs and 100% of Operations and Maintenance Costs, and:– May include in-kind services,– May include monies and in-kind services under an

administrative order on consent or judicial consent decree,

– May NOT include any funds pursuant to a unilateral administrative order or court order.

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Great Lakes Legacy Act Project Agreement

• Not a grant; not a contract

• Project Agreement (PA)

• A negotiated agreement between EPA and the non-Federal Sponsor

• Outlines roles and responsibilities of each party

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Great Lakes Legacy ActPartners

• Non-Federal Sponsors– States– Potentially responsible parties (PRPs)– Local consortiums

• Contractors– Remedial Action Contracts (RACs)– Emergency and Rapid Response Services (ERRS)– Superfund Technical Assessment & Response

Team (START)

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GLLA Quality Management

• Objective is to ensure the collection of supporting data that are scientifically sound, legally defensible, and of known and documented quality

• Provides a consistent approach to environmental decisions

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GLLA Quality Management

• Data Management must be “cradle to grave”– Project is not truly completed until project

information is compiled and available to stakeholders and the public

– Project information must be transparent and reproducible

– Completion of project reports are driving the process

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GLLA Data Management

• GLLA QMP stipulates that – sufficient documentation be provided with submission

of a data set to assist data users when evaluating the utility of the data set for their purposes

• includes the original information on data quality associated with the data

• supplementary information including data verification narratives

– quality documentation for each project addresses data management issues including collection, reporting, verification, and storage

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GLLA Data Management Challenges

• Dealing with multiple entities with distinct lines of authority

• Collaborators have their traditional ways of doing things

• Need to provide flexibility in data reporting but still capture required information

• Need to meet GLNPO/Federal policy of transparency and capture sample specific quality control data

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GLLA Data Management Challenges

• Need to be compatible with other data streams and data formats including Great Lakes Environmental Database and National Sediment Inventory

• Must handle data in different matrices including sediment, water and tissue

• Must handle data from biological analyses such as benthic invertebrate population data and toxicity data

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GLLA Data Management

• Allowable Data Reporting Formats1. Query Manager Template (with QC)

2. EPA Region V EDD 1. Right version

3. Staged Electronic Data Deliverable (SEDD)– With field data in QM template or Region V EDD– Stage 3 compatible– No field data

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GLLA Data Management Strategy

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GLLA Data Management

• Data Reporting Guidelines• Stand alone document currently included as

an attachment to the QMP• For submittal to contractors and laboratories

responsible for reporting data• Contains data standard templates, references

and user guides needed to report data • Includes section on locational data collection

and reporting – New!

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Case StudySediment Remediation(Project E)

• First GLLA project to use CLP serendipitously– START contractor conducted remediation– CLP labs used– Data turnaround very quick– Contract compliance screening (CCS) valuable and efficient– ESAT somewhat useful, but took another 60 days– Cost standardized– Lack of data usability review (e.g., merging of lab

and field data)– START contractor did not report QC data to EPA

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Project A

START contractor subcontracting to lab• Region 5 EDD• Data management degree of difficulty

– Medium

• Issues– Multiple submissions of data (requires confirmation of changes between

versions)– Multiple discussions with contractor to acquire (>9 months)

• Required QC data, • Batch information, • Definition of the laboratory reporting limits, • Data narratives• final validation flags (inconsistent application of validator flags versus lab-applied flags)• Definition of non-standard sample types• Subjective interpretation of data elements (use fields for their own purposes instead of

the intention of the data standard)

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Project B and C

Not for profit contractor subcontracting to lab• Data management degree of difficulty

– Data not yet received

• Issues– Project data interpretation is currently underway using

summary spreadsheets provided by the contractor– Report being developed– Requested data in Region EDD per the QAPP

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Project D

CLP program• Data management degree of difficulty

– Just receiving data

• Issues– Multiple labs reporting in different formats– Must relate laboratory data from these submissions to

common sampling station IDs

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Project E

Combination of CLP program and subcontracted laboratories through START contractor

• Data management degree of difficulty– Medium for CLP, High for non-CLP

• Issues– Batch information not provided. Were able to retrieve it for the

CLP data, but not for the non-CLP data.– MS/MSD data provided as amount found without spiking

information. Limits interpretation of these results.– Multiple QC results for a unique sample ID – Lab applied data qualifiers not defined.– Locational data missing for some samples.– Data verification narratives not provided for non-CLP

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Project F

CLP program• Data management degree of difficulty

– Medium

• Issues– MS/MSD data were provided as amount found. Recovery

had to be calculated. Working with SMO on alternatives for capturing these data.

– Reports from CLP are very informative and provide much of the information needed for upload to GLSED.

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Cost comparison

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Analyte

A (START contractor subbing to lab)

B (NFP contractor subbing to lab)

C (NFP contractor subbing to lab)

D (CLP)

E (CLP and contractor subbing to lab)

F(CLP)

VOA $132.18

PAH * $198.32

Pesticides $169.13 $109.20

Aroclors * $162.84 $110.66 $75.40

Metals * $69.17 ___ $51.75

Mercury $11.90 ___

Costs are final cost to GLNPO per sample

Recommendations

• Encourage adoption of SEDD across media– Few labs routinely reporting in SEDD outside of

CLP• Encourage minimum standardized field data

reporting• Headquarters track analysis by geographic

reference• Automated data review software for 2a and 2b

available to the Agency and contractors– EXES available across Agency and cooperators

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Recommendations

• Expand tools to work with non-traditional methods– toxicity, – TOC,– physical data, – Toxicity characteristic Leaching procedure (TCLP) for

permits

• Provide for flexibility in analytical methodology• Provide for project specific measurement quality

objectives

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Project Successes

• GLSED– Data for twelve projects has been uploaded into the

Great Lakes Sediment Database for a total of 93,000 records

– Database contains sample specific quality control results and data verification narratives

– Database was designed to simplify upload to the Great Lakes Environmental Database, CDX, and the National Sediment Inventory.

– May begin to include data quality label

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Conclusions• Involvement of multiple Regions, Program Offices, and

States, provides the best practices of each entity: Synergistic Response

• Empathy for Partners issues and concerns• Major cost savings• Lays out steps for improvement by partners

• If you do not document the quality of the data you are not going to have any problems until you make the wrong decision and you can not support controversial decisions

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“The Great Lakes Legacy Act Program has developed very comprehensive approaches for quality management that entail ‘cradle-to-grave’ QA requirements. These approaches adopt the best practices for sediment remediation and are endorsed by all stakeholders.”

R. Cheatham, EPA Headquarters Quality Management Review of GLNPO conducted in August 2006

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