United Slates
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
&EPA
DIRECTIVE NUMBER:
u
9375.1-4-1
TITLE: Appendix L, State-lead Quality Assurance Project
Plan Guidance
APPROVAL DATE: February 7, 1985
EFFECTIVE DATE: February 7, 19R5
ORIGINATING OFFICE: superfund
3 FINAL
D DRAFT
STATUS:
REFERENCE (other documents):
Addendum to State Participation in the Suoerfund
°rogram ''anual
OS WER OS WER OS WER
E DIRECTIVE DIRECTIVE D
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Unued Slates Environmental Protection Agency
rf\ 1— f-\ A Washington. DC 20460
V>EPA OSWER Directive Initiation Reauest
Originator Information
Name of Contact Person Mail Coda Teieonone NU
Deborah SvHchkow WH-54BE 582-2
Laaa Ortice PI (.iier Aoorovea tor Review
171 ««<. n Signature ol Office Director
IdJ OERR [J OWPE
D OSW Q AA-OSWER
Title
APPENDIX L, State-Lead Quality Assurance Project Plan
Guidance
Interim Directive Number
9375. 1-4-1-
m
Date
2/4/86
Summary of Directive
Provided to assist State staff members 1n developing, and Regional
staff 1n reviewing, Duality Assurance Project Plans (QAPPs).
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Addendum to State Participation 1n the Superf i ndQ Q^
Program Manual jg
if "Yet" to Either Question. What Directive tnum&tr. uttti
earlier addendum, <»/12/84 Q-z-i^^^L
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EL Revision
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Review Plan
O AA-OSWER Q OUST Q 0£CM D Omer (SptClW
IS OERR D OWPE D OGC
D OSW G Regiona D OPPE
This Request Meets OSWER Directive* System format
Signature of Lead Office Directives Officer
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Signature of 09WER 0(MCjiva»/QHicer
$Mtq0attyr
Date
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3JT-I&
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\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
° WASHINGTON. D.C. 20460
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
h-R 'f IQf-'f
r I_L> • i j j
MEMORANDUM
SUBJECT: Addenda to the State Participation in the Superfund
Program manual--Revisions to Appendix L, State Lead
Quality Assurance Project Plan Guidance
FROM: Sam Morekas, Chief /\ \\/l^\JL/v-*'~)
State and Regional -Coordination Branch
TO: Mailing List
Changes to Appendix L are editorial in nature. The
version of Appendix L which you currently have should he
discarded and be replaced with this attachment.
Attachment
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CHANGES TO DATE
1/31/86
9375.1-4
Date/
Addendum tt Topic
6/22/84 #1 Site Closeout
Minority and
Women's Business
Reporting
Changes to IG
Audit
9/12/84 #2
9/28/84 #3
Quality Assurance
Project Plan
Revised Letter of
Credit Procedures
Provision
Instruction
New pages
New page
New pages
New page
Change
"... which must
be sent within
120 days." to
"... which
must be sent
within 90 days."
Add, as the
second sentence
in the para-
graph, "In
addition, the
Award Official
will send the
State a copy of
the final audit
report within 15
days of its
receipt."
Change "The re-
sponse must be
dispatched with-
in 120 days..."
to "The response
must be dis-
patched within
90 days..."
New pages
Replacement pages
Location/Page
Appendix F, Pages F-22
and 23
Appendix H, Page H-23
Appendix P, Pages
P-37-P-47
Appendix F, Page F-24
Appendix C, Page C-12,
first complete paragraph
Appendix C, Page C-12
first complete paragraph
Appendix C, Page C-12
footnote
Appendix L, formerly
reserved
Appendix F, Pages F-3
through F-6
111
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CHANGES TO DftTE (Continued)
Date/
Addendum #
12/10/84 #4
Multi-Site Coop-
erative Agreements
Instruction
Replacement
pages
Replacement
pages
Replacement
pages
Replacement
pages
New pages
Replacement
page
New pages
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pages
New pages
Replacement
page
New page
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pages
New page
Change "...at
quarterly inter-
vals commencing
at the start of
the project." to
"...within 30
days of the end
of the Federal
fiscal quarter."
New pages
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pages
New pages
Replacement
pages
Replacement
pages
New pages
1/31/86
9375.1-4
Location/Page
Table of Contents, Pages
xiii through xvii
List of Exhibits, Pages
xvii and xix
List of Acronyms, Pages
a - through e
Chapter II, Pages II-l
through 6
Chapter II, Page II-7
and Exhibit II-2
Chapter III, Page 111-17
Chapter III, Pages
111-18 through 27 and
Exhibits 111-10 and
III-ll
Chapter IV, Pages
IV-5 through IV-7
Chapter IV, Pages IV-8
through iv-ll
Chapter V, Page V-7 and
V-8
Chapter V, Page V-9
Appendix E, Pages E-l
through E-22
Appendix E, Page E-23
Appendix F, Page F-16,
Section K, indented
paragraph
Appendix F, Pages F-25
and F-26
Appendix J, Pages J-l,
J-2, and J-7
Appendix J, Pages J-8
and J-9
Appendix N, Pages N-l
through N-6
Appendix P, Pages P-l,
P-2, and P-47
Appendix P, Pages P-48
through P-51
IV
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Date/
Addendum #
Topic
CHANGES TO DATE (Continued)
Instruction
1/4/85 #5 Advance Match
1/11/85 #6 Site Safety Plan
Guidance
8/2/85 #7 Obtaining Equipment
Under a CERCLA
Cooperative Agreement
9/17/85 #8 Intergovernmental
Review Procedures
State Cooperative
Agreements for Pre-
Remedial Activities
12/18/85 #9 Action Memorandum
Guidance
12/20/85 #10 Model Statement of
Work for a Remedial
Investigation/
Feasibility Study
12/20/85 #11 Site Safety Plan
Guidance
1/31/86 #12 Quality Assurance
Project Plan
New pages
New pages
New pages
. Replacement page
. Replacement pages .
•
. New pages
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Replacement pages
. Replacement pages .
•
. Replacement pages .
. Replacement pages .
. Replacement pages .
1/31/86
9375.1-4
Loca tion/Page
New Appendix S, Pages
S-l through S-9
Appendix M, formerly
reserved
New Appendix T, Pages
T-l through T-15
Table of Contents, Pages
xiii through xix
List of Exhibits, Pages
xx and xxi
Appendix D, Pages D-l
through D-28
Appendix A, formerly
reserved
Table of Contents, Pages
xiii through xix
Appendix B, Pages
B-l through B-9
Table of Contents, Pages
xiii through xix
Appendix E, Pages
E-l through E-21
Table of Contents, Pages
xiii through xix
Appendix M, Pages M-l
through M-28
Table of Contents, Pages
xiii through xix
Appendix L, Pages L-l
through L-12
iva
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TABLE OF CONTENTS
1/31/86
Revised Page xiii
9375.1-4
DATE
LIST OF ACRONYMS AND ABBREVIATIONS
I. INTRODUCTION
A. Purpose of the Manual
B. Background — Key Terms
B.I Remedial Response
B.2 Remedial Response Agreements
B.3 State Assurances
B.3.a Cost-Shar ing
B.3.b Off-Site Treatment, Storage,
or Disposal
B.3.C Operation and Maintenance (O&M)
B.4 State Credits
C. Overview of the Manual
II. CONCURRENT ADMINISTRATIVE EVENTS
A. Initiation of Enforcement Activities
B. Initiation of Forward Planning
C. Development of Site-Specific Schedules
D. Development of the Remedial
Accomplishments Plan (RAP)
E. Development of the Action Memorandum
F. Identification and Review of State
Credit Submissions
G. Intergovernmental Review
III. DEVELOPMENT OF COOPERATIVE AGREEMENT
APPLICATION PACKAGES
A. Completion of the Cooperative Agreement
Application Form
12/10/84
PAGE
a
1-1
1-2
1-3
1-4
1-4
1-5
1-5
1-6
1-7
1-7
1-7
II-l 12/10/84
II-2
II-2
II-5
II-5
II-5
II-6
II-7
III-l
III-2
Xlll
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9375.1-4
PAGE DATE
A.l Part IV - Project Narrative III-2
Statement
A.2 Part III - Project Budget II1-3
A.2.a Allowable Costs II1-4
A.2.b Enforcement Costs II1-5
A.2.c Calculation of State Cost Share III-5
B. Development of Cooperative Agreement II1-6
Provisions
B.I General Assistance Requirements II1-6
B.2 Superfund Program Requirements II1-7
B.2.a Provision of CERCLA II1-8
Section 104(c)(3) Assurances
B.2.b The National Environmental II1-9
Policy Act of 1969 (NEPA)
B.2.c Quality Assurance/Quality III-lO
Control (QA/QC)
B.2.d Site Safety Plan III-il
B.2.e Expedited Procurement II1-12
C. Completion of the Procurement System II1-12
Certification Form
D. Other Submissions II1-13
D.I Community Relations Plan (CRP) 111-13
D.I.a Draft Community Relations II1-13
Plan
D.l.b Complete Community II1-14
Relations Plan
D.2 Certification Letter 111-15
D.3 Intergovernmental Review Comments II1-15
E. Deviation Requests to Permit the I11-15
Allowability of Pre-Award Costs
F. Multi-Site Cooperative Agreements 111-17 12/10/84
F.I Activities That May Be Included 111-18
in Multi-Site Cooperative
Agreements
F.2 Intergovernmental Review II1-19
F.3 Contents of a Multi-Site Cooperative II1-20
Agreement
xiv
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F.3.a Cooperative Agreement
Application Form
F.3.b Multi-Site Cooperative
Agreement Application
Provisions
F.3.c Procurement System
Certification Form
F.3.d Certification and
Enforcement Letters
F.4 Accounting for Multi-Site
Cooperative Agreements
F.5 Administration of Multi-Site
Cooperative Agreements
F.5.a Proj ect Management
F.S.b Project/Budget Periods
F.S.c Quarterly Reports
1/31/86
Revised Page xv
9375.1-4
PAGE
111-20
111-23
111-23
111-23
111-24
111-26
111-26
111-26
111-27
DATE
IV. DEVELOPMENT OF EPA-LEAD REMEDIAL PLANNING
AGREEMENTS
A. The Scope of Work for Remedial Planning
B. Documentation of Terms and
Respons ibi1ities
B.I EPA Responsibilities
B.2 State Responsibilities
B.3 General Terms
C. Other Submissions
C.I Community Relations Plan (CRP)
C.2 Intergovernmental Review Comments
D. Management Assistance Cooperative
Agreements
V. DEVELOPMENT OF SUPERFUND STATE CONTRACTS
A. Development of the Statement of Work (SOW)
B. Development of State Cost-Sharing Terms
B.l Calculation of the State's Cost Share
B.2 Negotiation of Payment Terms
C. Documentation of Other Terms ancf
Responsibilities
IV-1
IV-3
IV-3
IV-3
IV-4
IV-4
IV-5
IV-5
IV-6
IV-6 12/10/84
V-l
V-2
V-2
V-2
V-3
V-4
XV
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1/31/86
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9375.1-4
C.I EPA Responsibilities
C.2 State Responsibilities
C.3 General Terms
D. Other Submissions
D.I Community Relations Plan (CRP)
D.2 Certification Letter
D.3 Intergovernmental Review Comments
E. Multi-Site Superfund State Contracts
PAGE DATE
V-4
V-5
V-6
V-7
V-7
V-8
V-8
V-8 12/10/84
VI. EXECUTION OF REMEDIAL AGREEMENTS VI-1
A. Review of the Draft Agreement VI-l
A.I Review of the Draft Cooperative VI-2
Agreement Application Package
A.2 Review of the Draft EPA-Lead VI-2
Submission
B. Final Regional Review and Preparation VI-2
of the Concurrence Package
C. Approval and Execution VI-4
VII. ADMINISTRATION OF REMEDIAL AGREEMENTS VII-1
A. Monitoring Financial Commitments VII-1
A.I State Drawdowns Under a Cooperative VII-2
Agreement
A.2 State Payment of Cost Share Under VI1-3
a Superfund State Contract
B. Monitoring Technical Commitments VI1-3
B.I Monitoring Site Activities VII-4
B.2 Monitoring State Assurances and VI1-5
Compliance with Special Conditions
C. Coordinating EPA-Lead Remedial Agreements VI1-5
with Performance Agreements
D. Documenting Remedial Activity VII-6
xvi
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D.I Regional Files
D.2 EPA Headquarters Files
D.3 State Files
Documenting Completion of Remedial
Implementation [RESERVED]
1/31/86
Revised Page xvii
9375.1-4
PAGE DATE
VI1-6
VII-6
VI1-7
VIII. AGREEMENT MODIFICATIONS
A. Project Adjustments
A.I Adjustments to State-Lead Projects
A.2 Adjustments to EPA-Lead Projects
B. Initiation of Remedial Design and
Remedial Action
B.I Records of Decision (RODs)
B.2 Incorporating Remedial Design and
Remedial Action into an
Agreement Between EPA and the State
VIII-1
VIII-1
VIII-1
VII1-2
VII1-3
VIII-3
VIII-6
C. Initiation of Operation and Maintenance VIII-7
xvii
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9375.1-4
APPENDICES
Introduction to
Appendix A -
Appendix B -
Appendix C -
Appendix D -
Appendix E -
Appendix F -
Appendix G -
Appendix H -
Appendix I -
Appendix J -
Appendix K -
Appendix L -
Appendix M -
Appendix N -
Appendix 0 -
Appendix P -
Appendix Q -
the Appendices
PA/SI Guidance
Action Memorandum Guidance
A-l 9/17/85
B-l 12/20/85
Procedures for Developing and Processing C-l
CERCLA State Credit Claims
Procedures for Implementing Intergovern- D-l 9/17/85
mental Review
Model Statement of Work for State-lead E-l 12/10/84
Remedial Investigation/Feasibility Study
Projects
Sample Cooperative Agreement Application F-l
Provisions
Sample Cooperative Agreement Application G-l
Package
Sample Articles for Superfund State
Contracts and Other EPA-Lead Remedial
Agreements
Sample Superfund State Contract
Sample Certification Letters
Sample Community Relations Plan Format
and Sample Plan (CRP)
H-l
1-1
J-l 12/10/84
K-l
Sample Quality Assurance/Quality Control L-l 1/31/86
Plan
Sample Site Safety Plan
Instructions for Using Superfund Letter
of Credit Account Numbers Under
Cooperative Agreements
Record of Decision (ROD)/Enforcement
Decision Document (EDO) Guidance
Selected EPA Policy Papers
Glossary of Terms
xviii
M-l 12/20/85
N-l 12/10/84
O-l 1/17/86
P-l
Q-l
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Revised Page xix
9375.1-4
Appendix R - List of References R-1
Appendix S - Advance Match Procedures S-l 1/4/85
Appendix T - Obtaining Equipment for Use Under T-l 8/9/85
a CERCLA Cooperative Agreement
xix
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APPENDIX L
STATE-LEAD QUALITY ASSURANCE PROJECT
PLAN GUIDANCE
OSWER DIRECTIVE
9375.1-4-1
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9375.1-4-1
APPENDIX L
STATE-LEAD QUALITY ASSURANCE PROJECT PLAN GUIDANCE
PURPOSE
This appendix has been provided to assist State staff
members in developing, and Regional staff in reviewing,
Quality Assurance Project Plans (QAPPs)*. Its primary
objectives are to:
Highlight and make States aware of their quality
assurance responsibilities in all phases of the
QAPP preparation and implementation process
Provide detailed supplemental instructions to
States in addressing the 16 major elements of
QAPPs as specified in EPA's "Interim Guidelines
and Specifications for Preparing Quality Assur-
ance Project Plans"QAMS-005/80
Ensure that all environmental sampling and analy-
sis conducted as part of Superfund projects meets
Superfund quality assurance requirements
Speed up the documentation or development of
acceptable QAPPs.
The detailed guidance that is found in this appendix is
based on guidance developed by the Region V Quality As-
surance Office.
BACKGROUND
Remedial investigation QAPPs are prepared to attain
data quality goals for monitoring activities at a specific
hazardous waste site. A QAPP describes, in specific, suc-
cinct terms, the 1) policy, 2) organization, 3) functional
activities (sample collection, chemical analyses, etc.)
and 4) quality assurance
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9375.1-4-1
Quality assurance can be defined as the mechanism used
to verify that an analytical process is operating within
acceptable limits and is producing data of acceptable
quality. The most important factor in determining the
level of QA and QC required for a monitoring activity is
the consequence of being wrong.
As part of EPA policy and regulation, QAPPs are pre-
pared and approved prior to the initiation of an EPA-
funded sampling program (see 40 CFR 30.503(f) and (g)>. A
QAPP organizes, in a logical format, the general guide-
lines to be followed in conducting environmental analy-
sis. "Interim Guidelines and Specifications for Preparing
Quality Assurance Project Plans," QAMS-005/80, U.S. EPA,
December 1980, is the current EPA guidance document for
preparation of QAPPs. QAMS-005/80 specifies 16 elements
that must be considered in a QAPP; this document should be
followed by State personnel managing State-lead remedial
activities.
Each of the 16 QAPP elements can be prepared indivi-
dually or may be documented by reference, as appropriate.
Each element should be tailored to the specific needs of a
monitoring project or response activity. However,
QAMS-005/80 does not provide detailed guidance on the de-
velopment of all QAPP elements. Additional guidance on
developing some of the 16 elements may be found in
"Guidance for Preparation of Combined Work/Quality As-
surance Project Plans for Water Monitoring," Office of
Water Regulations, U.S. EPA, March 1983. Copies of the
above document may be obtained from Regional QA/QC of-
fices. Section II of the above document provides more
detailed guidance on preparation of several of the 16
elements.
QA and QC roles in, and definitions for, a monitoring
activity are discussed effectively in two of the re-
ferences cited in the bibliography for this appendix.
These articles are entitled "Principles of Environmental
Analysis" and "Quality Assurance of Chemical Measure-
ments;" copies of these articles may be obtained from the
Regional QA/QC officer. They document that QA and QC are
a recognized and integral part of a technically sound en-
vironmental monitoring program or response activity.
L-2
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9375.1-4-1
APPENDIX SUMMARY
This appendix contains guidance on QAPPs. It is to be
used by State and Regional EPA staff members, vith appro-
priate modifications, when preparing QAPPs for inclusion
in Cooperative Agreement application packages or during
Regional review of these plans.
L-3
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Revised Page L-4
9375.1-4-1
ELEMENTS OF A STATE-LEAD REMEDIAL QAPP*
A. Approvals
State-lead remedial activities are extramural projects
as defined by page 1 of Section 4 of QAMS-005/80. As
such, the QAPP must be reviewed by a State Quality As-
surance Officer and approved by the State Project Officer
(SPO). Likewise, after it is submitted to EPA it should
be reviewed by the Regional Quality Assurance Office and
approved by the Remedial Project Manager (RPM). A Region
may specify that a QAPP receive more levels of review
authority and approval, however, should this be deemed
necessary.
B. State-Lead Responsibilities
The State is responsible for preparing the QAPP. It
may develop the QAPP itself or may use its contractor(s)
to assist in this task. In either case, at least the fol-
lowing elements of the QAPP should be prepared prior to or
during development of a sampling plan:
Project Description
Project Organization and Responsibility
QA Objectives.
These elements are explained more fully below.
In developing the QAPP, the State must be aware of its
responsibility to meet Superfund program QA requirements
in all environmental sampling and/or analysis conducted as
part of the project. These requirements, identified in
Chapter III of this manual, are Agency policy and relate
to the needs of litigative proceedings, cost-effectiveness,
and timeliness.
The Contract Laboratory Program (CLP) can be used to
conduct necessary environmental analysis or the State may
use its own facilities for this purpose. In either case,
the State should identify in its application those labora-
tory facilities that it intends to use. The Users Guide
to the EPA Contract Laboratory Program (available from
Regional Quality Assurance Offices) provides a breakdown
QAPPs should be prepared using the document control
format (see the upper right-hand corner of each page
of QAMS-005/80). This allows easy changes to be made
without rewriting the entire document.
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9375.1-4-1
of the types of analytical services that the CLP provides;
this guide can be used for purposes of comparison with
State facilities. Regional project or QA staff can pro-
vide the State with CLP information.
The State also is responsible for ensuring that any
laboratory analyzing samples has needed protocols speci-
fied in the approved QAPP.
C. Project Description
A precise project description defines the scope of the
remaining QAPP elements. To ensure that it does this, the
Project Description should contain the following items:
A succinct description of the project, including
a brief statement addressing the project's objec-
tives (purposes); an overview of the project's
scope or complexity; and background information
from previous studies of the project area, if
appropriate.
Dates anticipated for start and completion of the
project and sampling activities.
A brief statement outlining intended data us-
age(s). These may include, but are not limited
to, future enforcement actions, data for assess-
ing remedial action alternatives, determination
of hazardous waste characteristics for remedial
and removal activities, protection of public
health, definition of the extent of environmental
contamination, etc. Future regulatory actions
under such laws as the Resource Conservation and
Recovery Act (RCRA), CERCLA, and the Safe Drink-
ing Water Act may (or may not) dictate analytical
methods and chain-of-custody protocols to be used.
A brief description of the sampling network de-
sign and rationale.
A discussion of the sample matrices and parame-
ters to be measured and their frequency of col-
lection, if appropriate. Parameters should in-
clude any field measurements (pH, conductance,
etc.) and hydrogeological investigations (such as
soil permeability, particle size analysis,
etc.). Sample matrices and parameters are best
listed in two groups:
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Revised Page L-6
9375.1-4-1
On-site sludges, barrels, liquids, contami-
nated soils, etc., which often are analyzed
to determine treatment or disposal methods.
Ambient monitoring of air, ground water,
soils, surface water, river sediments, fish,
etc., which measure the extent of environ-
mental contamination and assess public
health risks. Any specifications for fil-
tered or unfiltered sample groundwater ali-
guots should be specified and included as
part of a definition of parameters.
The latter two types of determinations discussed above us-
ually dictate two types of sampling and analytical proto-
cols. Quality assurance protocols can be expected to be
different for each type of determination.
The remedial program office in the Region should re-
view the QAPP Project Description to ensure that it is ac-
curate and meets the needs of the proposed remedial activ-
ity prior to any further review by the Regional Quality
Assurance Office.
D. Project Organization and Responsibility
This element of the QAPP should identify key organiza-
tions and individuals, as appropriate, responsible for:
Overall QA/QC (State agency).
Sampling operations and QC (State agency and/or
contractor).
Laboratory analyses and laboratory QC. All la-
boratories, including those subcontracting to a
State contractor, must be identified. If the CLP
is to be used, it also should be identified.
Overall QA. The State or Federal organization
responsible for overall QA review for the reme-
dial activity must be specified. QA overview can
be provided by the State agency (prime responsi-
bility) , the Regional Quality Assurance Office,
and the contractor operating under the direction
of the Regional Quality Assurance Office. If the
CLP is to be used during a State-lead remedial
activity, this QAPP element also should define
responsibility for 1) final data review of
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Revised Page L-7
9375.1-4-1
routine CLP services, 2) preparation and final
data review of CLP and Special Analytical Ser-
vices, and 3) review and confirmation of any ten-
tatively identified organic compounds from gas
chromatography/mass spectroscopy (GC/MS) library
searches.
Performance (unknown reference samples) and sys-
tems audits (on-site laboratory evaluations).
The State agency may have overall QA responsi-
bility; however, this function may be performed
by organizations other than the prime State
agency, such as through an agreement with a State
health department.
Regional review of the Project Organization and Responsi-
bility element of a State-lead QAPP is the joint responsi-
bility of the remedial program office and the Regional
Quality Assurance Office.
E. Quality Assurance Objectives for Data Measurement in
Terms of Precision, Accuracy, Completeness, Represen-
tativeness, and Comparability
Sound QA objectives require careful thought and input
from analysts and the individuals who will use the
resulting data. These objectives need to be established
before monitoring is begun. Objective development should
be the primary responsibility of the State agency and not
that of the contractor actually conducting the remedial
activity. Regional review of the QA Objectives element of
a State-lead QAPP is a joint responsibility of the reme-
dial program office and the Regional Quality Assurance
Office.
1. Precision and Accuracy
For each matrix (or matrix group) and parameter, the
State agency should define and provide objectives for:
Level of QA effort
Accuracy (sample spikes, surrogate spikes,
reference samples, etc.)
Precision (replicate sample analyses, etc.)
Sensitivity or method detection limits.
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9375.1-4-1
These objectives should be established on the basis of in-
dividual project needs, if possible, but must be discussed
with support laboratories so that they are realistic.
Quantitative limits also should be established for the
above objectives. For example, mean spike recoveries for
volatile halogenated organic compounds in water using
purge and trap gas chromatography techniques should be
90-110% and range between 80 and 120% recovery. Results
of reference sample analyses should be accurate within
+ 20% of true values. Precision objectives should be that
duplicate sample aliquot values differ no more than + 10%
at the 95% confidence level when concentrations measured
are significantly larger than the method detection limit.
Except for methylene chloride, method detection limit ob-
jectives realistically can be established at 0.2ug/l for
this gas chromatography technique. On the other hand,
screening of hazardous waste site liquids may require only
50 to 150% recovery of spike surrogate compounds during
GC/MS determinations and method detection limits of 10
ug/1 for volatile halogenated organic compounds.
Selection of analytical methods also requires fa-
miliarity with any regulatory requirements of intended
data usage(s). Superfund programs presently have no
analytical methods required by regulation; however, dis-
posal of wastes during remedial and removal activities
will require testing of materials pursuant to RCRA. In
this case, RCRA regulations may dictate choices of
analytical methods for Superfund projects.
2. Completeness, Representativeness, and Comparability
For most remedial activities the terms "completeness",
"representativeness", and "comparability" are quality
characteristics that should be considered during study
planning. It is expected that laboratories will provide
data meeting QC acceptance criteria for 90% or more of the
determinations requested. At the same time, it is incum-
bent on planners to identify any sample types, such as
controls, which require 100% completeness. If these sam-
ple types are identified in advance, apparent loss of data
can be corrected by appropriate resamples. Representa-
tiveness generally is viewed as collection of representa-
tive samples (compositing if appropriate) or selection of
representative sample aliquots during analysis. Compar-
ability should be considered during planning so that
inconsistencies between different agencies' data or
between different analytical methods can be avoided.
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F. Other Elements
Standard operating procedures (SOPs) or statements
should be provided for the remaining elements of the QAPP
(identified on pages 1 and 2 of Section 3 of QAMS-005/80).
These elements are best prepared after drafts of the Pro-
ject Description, Project Organization and Responsibility,
and QA Objectives sections are available. Details of
these elements should be consistent with the parameters
and sample matrices identified in the Project Description
and in the QA Objectives elements. If accurate SOPs are
available in standard references (e.g. "Standard Methods
for the Examination of Water and Wastewater") or existing
State Agency or contractor manuals, they may be provided
by reference if these documents are readily available.
The choice of when to reference a manual's test pro-
cedure and when to document a complete SOP should be made
on a case-by-case basis. Few laboratories, other than the
CLP, exactly follow all important details of a standard
reference method. Usually standard reference methods pro-
vide or allow options such as the use of different gas
chromatography columns for PCB determination. It may be
appropriate to reference analytical methods in a State
agency manual or "Standard Methods"; however, required
sample preparation procedures (filtration, digestion,
etc.) also should be referenced. For example, EPA's
"Methods for Chemical Analysis of Water and Wastes" pro-
vides three different test procedures for most metal de-
terminations and at least four sample preparation proto-
cols for each metal. Different quality control audits are
used for each combination of metal determination and sam-
ple preparation. For this reason, it is necessary to spe-
cify the exact combination used for each metal.
In addition to the three QAPP elements discussed
above, QAPP preparers should pay special attention to the
following elements:
Sampling Procedures — This element is properly
detailed on pages 4 and 6 of Section 5,
QAMS-005/80. Many of the details necessary to
complete this section should be available within
a remedial action sampling plan. Field measure-
ments or hydrogeological investigations may be
documented either in this element or in the An-
alytical Procedures portion of the QAPP, outlined
below.
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Sample Custody — U.S. EPA sample custody or
chain-of-custody protocols are described in "NEIC
Policies and Procedures," EPA-330/9-78-001-R, Re-
vised February 1983. There are three parts to
custody requirements: sample collection, labora-
tory handling, and final evidence files. Final
evidence files include all originals of labora-
tory reports and are maintained under documented
control in a secure area. A sample or evidence
file is under custody if: 1) it is in one's pos-
session, or 2) it is in one's view after being in
one's possession, or 3) it was in one's posses-
sion and was locked up, or 4) it is in a desig-
nated secure area. The Regional remedial pro-
gram office is responsible for determining the
need for chain-of-custody at a State-lead re-
medial activity; the Regional Quality Asurance
Office will review a QAPP chain-of-custody proto-
col for consistency with the NEIC's protocol
requirements. A QAPP should provide examples of
chain-of-custody records or forms used to record
chain-of-custody for samplers, laboratories, and
evidence files.
Calibration Procedures and Analytical
Procedures — Calibration and analytical proce-
dures often are combined as part of a specific
analytical methodology. If the CLP is to be
used, reference should be made to specific CLP
Invitations for Bids. If special analytical ser-
vices are to be used for the CLP, they should be
part of the QAPP, included under this element.
Internal Quality Control Checks — This element
should outline the protocols actually being
followed for each test or determination (e.g.
sample spikes, surrogate spikes, independently
prepared reference samples or controls, blanks,
etc.). The frequency of these audits should be
specified. The compounds used for surrogate and
sample spikes also should be specified, where
appropriate (e.g. arsenic, mercury, priority pol-
lutant organic compounds, etc.). The acceptance
limits or control chart limits for these audits
should be provided. Acceptance limits for qual-
ity control audits should be in place so that an-
alyses can be validated prior to data reporting.
If the CLP is being used, reference to specific
Invitations for Bids will be sufficient to des-
cribe this element.
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Performance and System Audits — Completion of
these audits is the responsibility of the State.
The State should provide QA oversight to its con-
tractor laboratories prior to initiation of a
project.
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BIBLIOGRAPHY*
"Guidance for Preparation of Combined Work/Quality
Assurance Project Plans for Water Monitoring," EPA/
Office of Water Regulations and Standards, March 1983.
"Interim Guidelines and Specifications for Preparing
Quality Assurance Project Plans," QAMS-005/80, U.S.
EPA, December 1980.
"NEIC Policies and Procedures," EPA 330/9-78-ooi-R,
revised February 1983.
"Preparation of State-Lead Remedial Investigation
Quality Assurance Plans for Region V," EPA Region V
Quality Assurance Office, April 4, 1984.
"Principles of Environmental Analysis," American
Chemical Society, Committee on Environmental Improve-
ment, Anal. Chem., 55, 2210 (1983).
"Quality Assurance of Chemical Measurements," Taylor,
A.K., Anal. Chem., 53 1588 A (1981).
Documents cited are available from Regional Quality
Assurance Offices.
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