xvEPA
United States
Environmental Protection
Agency
November 2012
EPA 542-R-12-005
Office of Solid Waste and Emergency Response (OSWER)
Brownfields Grant Recipients' Road Map to
Understanding Quality Assurance Project Plans
Purpose of this Roadmap
The U.S. Environmental Protection Agency prepared this publication to help
recipients of an EPA Brownfields Assessment Grant (recipients) design and
complete site assessment projects more efficiently and effectively by increasing
their awareness and understanding of the importance of quality assurance (QA)
in Brownfields site projects. This document also provides an overview of EPA
requirements for developing generic and site-specific quality assurance project
plans (QAPP) and site-specific QAPP addendums (collectively 'QAPPs') in support
of site assessment efforts at Brownfields sites. Readers are advised that specific
QAPP requirements will vary by EPA region and state. Finally, the document
outlines a general process to help recipients oversee their environmental
contractor's efforts to develop QAPPs to ensure collection of adequate and
appropriate data to support the decision-making processes needed to determine
and support protective future uses of Brownfields sites.
Quality assurance (QA) for Brownfields
sites involves planning and managing
the process for gathering and using
environmental data to ensure they are
of the right type, quantity and quality
necessary to make a decision. The
quality assurance project plan (QAPP)
documents the quality process and
addresses in the appropriate formats the
specific quality elements required by the
relevant EPA region and state.
Quality Assurance - What it is and
Why It's Important
Most people consider the quality of a
product or service before they decide
to purchase it. As a result,
manufacturers and service providers
are compelled to implement QA to
ensure customers are satisfied with
their products and services. QA includes
organizing and planning for quality;
^^^
collecting data and completing quality
control (QC) checks; documenting, evaluating and reporting QC check findings;
and acting to address identified quality issues. Successful QA processes are
thorough, well-documented and designed to ensure that the outcomes achieved
meet the quality required. For environmental projects, QA processes are
implemented to ensure that the data obtained in support of environmental
assessment and cleanup are of an appropriate quality for their intended
purposes. This level of quality is critical because these data drive decisions
regarding the need for, and degree of, remediation and other controls required
at a site to protect human health and the environment.
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The Brownfields QAPP Road
Map below illustrates the
general process for
developing, submitting and
obtaining approval of
Brownfields QAPPs.
BEGIN HERE
Prepare for QAPP
Development Effort
Step 1. Establish
Project Team
Step 2. Develop Data
Quality Objectives &
Decision Criteria
Step 3. Develop
Draft QAPP
Step 4. Review and
Revise QAPP
Submit QAPP
for EPA and State
Approval
Step 6. Implement,
Monitor and
Document Progress
PROJECT
COMPLETE
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The EPA requires that a QAPP
be prepared to support all
federally-funded environmental
projects involving the
collection, evaluation, use and
reporting of environmental
data.
www.epa.Rov/irmpoli8/
olicies/21060.odf
Preparation Activities
S Review this Road Map and
other QAPP-related
resources
•S Contact EPA Brownfields
project officer
•S Contact state project
manager and others
recommended by the EPA
Brownfields project officer
(such as EPAQA
personnel)
S Obtain, review and share
available tools, resources,
formats and guidance
specific to the EPA region
and state
Brownfields Grant Recipients' Road Map to Understanding Quality Assurance Project Plans
General Process for Completing QAPPs for Brownfields Sites
This document describes the general process that recipients can follow to
prepare for, develop and implement generic QAPPs, site-specific QAPPs and site-
specific QAPP addendums. It identifies the basic components of a QAPP and
describes the organizational relationships and typical roles and responsibilities of
those directly involved in QAPP development and implementation. More
information on the performance of Brownfields site assessment and cleanup
efforts is available in the "Brownfields Road Map to Understanding Options for
Site Investigation and Cleanup, Fifth Edition/' which is available for download
and interactive access at www.brownfieldstsc.org/roadmap.
The general steps and activities described are supported by a companion
checklist included in Appendix A, which recipients can use to track the progress
of QAPP development efforts on their projects. The checklist is primarily
provided for recipients with limited to no prior Brownfields site assessment
project experience; as sometimes may be the case for city planners, community
or development coordinators, city administrators, city engineers or elected
officials.
Prepare for QAPP Development Effort
The first step in preparing for QAPP development is to
understand its purpose and the general process and activities
involved. The main purpose of a QAPP is to serve as the
instruction manual or 'game plan' for site assessment or
cleanup, with specific emphasis on ensuring the quality of field sample and
measurements data collection, sample analysis and subsequent data validation,
evaluation and reporting. Due to its collaborative nature, the QAPP development
process helps ensure that key project stakeholders have a common
understanding of technical quality and performance expectations.
A generic QAPP may be developed when a Recipient's Brownfields program
involves more than one site and is designed to accommodate technical
requirements common to all of the sites. A site-specific QAPP addendum
supplements the generic QAPP, usually in the form of a sampling and analysis
plan (SAP), and addresses the additional and unique technical issues of
performing a site assessment at one or more sites. Site assessment goals,
approaches and technologies can differ significantly for each site based on
variability in major site attributes such as contaminant types, depth of
groundwater, site geology, overall site conditions and accessibility. If one or
more sites of interest in a multi-site program are known at the time, there are
schedule and cost benefits in developing the generic QAPP and site-specific
QAPP addendum simultaneously, or alternatively, separate site-specific QAPPs.
Otherwise, the documents are typically developed and approved in succession. A
Page 2 of 20
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Brownfields Grant Recipients' Road Map to Understanding Quality Assurance Project Plans
site-specific QAPP includes all of the elements of a generic QAPP and a SAP and
is developed for application to one site.
Generally, there are four major components of a QAPP; each comprised of a
number of subcomponents that address key information required to execute a
quality project. Figure 1 provides an overview of these components; while
Appendix B lists and describes each subcomponent in detail.
Different EPA regions and states have unique technical requirements and
organizational and procedural aspects for implementing and overseeing QAPP
development (For internet access to Regional resources, see "Regional QA
Technical Resources Webpages" on page 12). Recipients should communicate
with their Regional EPA Brownfields project officer and state Brownfields project
manager to confirm the specific QAPP requirements and process used for
Brownfields QAPPs in their location. In addition, recipients will need to identify
and obtain input from any other potentially significant decision-makers for their
program and or sites; such as other state regulating agencies; and state, county
and city planning and development organizations.
Figure 1 - General Quality Assurance Project Plan Components
Data Acquisition and Management
Describes how and where samples will be
collected, transported, analyzed and
recorded (including site maps, reference to
standard operating procedures (SOPsJ and
identification of analytical methods).
Assessment and Oversight
Describes the types and frequencies of
quality assessments that will be conducted
by the project team to ensure that project
quality goals are met as the project
progresses.
Project Management
Identifies key team members, roles and
responsibilities, site background, the
problem to be addressed and other
information related to project management
and communication.
QUALITY
ASSURANCE
PROJECT PLAN
COMPONENTS
Data Validation and Usability
Describes how data will be evaluated before
it is used in the decision-making process for
the site.
The responsible federal and state personnel can provide resources such as
guidance documents (beyond those listed in the references on pages 12 and 13),
QAPP outlines and templates and examples of QAPPs they have previously
approved for similar projects. Because QAPPs are scalable, the cost and time to
produce them can vary, so recipients should seek clarity on the appropriate
amount of information and degree of detail needed to support their program
and site projects. The EPA or state may also encourage the use of streamlined
formats, such as the Uniform Federal Policy Quality Assurance Project Plan (UFP-
QAPP) (IDTQF, 2004) to expedite QAPP development and review, as well as
innovative strategies and field-based screening technologies to support more
effective site assessments.
PageS of 20
Typical Types of QAPPs
Generic QAPP - applies to all
sites in a multi-site program.
Site-Specific QAPP Addendum
- applies to one or more sites
in a multi-site program.
Commonly submitted in the
form of a sampling and
analysis plan (SAP).
Site-Specific QAPP -
submitted when a Brownfields
program is limited to one site
or when separate QAPPs are
developed for each site in a
multi-site program. Includes a
SAP.
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Step 1 Activities
•S Establish project team
S Identify other needed
team members and begin
to locate them
•S Initiate development of
Project Management
components of QAPP using
the formats obtained
under Step 1
•S Identify State and Regional
requirements applicable to
the site
S Prepare an RFP to hire a
contractor and/or
laboratory to complete the
Project Team
Brownfields Grant Recipients' Road Map to Understanding Quality Assurance Project Plans
Step 1: Establish Project Team
The typical Brownfields recipient's project team includes
personnel from the recipient's organization, personnel from the
recipient's environmental contractor and the contractor's
subcontractors (such as drillers, specialty field services providers
and laboratories). The EPA and state Brownfields personnel
support the team with guidance, quality review and QAPP approval authority.
In close partnership with the recipient, the environmental contractor typically
leads the technical design and execution of the recipient's Brownfields site
assessment project; including, but not limited to, QAPP development, field and
analytical program implementation and project reporting. In addition,
environmental contractors frequently provide recipients with technical and
outreach support for meetings and presentations to the EPA, state, other project
stakeholders and the community at large. If a recipient has more than one
environmental contractor, each will develop QAPPs and support the Recipient
with additional services for the projects they are assigned to support.
Figure 2 shows the organizational structure and roles of a typical Brownfields
recipient's site assessment team, including the relationships with EPA and state
personnel and the significant role of the environmental contractor and its
subcontractors.
Figure 2 - Typical Brownfields Grant Recipient's Site Assessment Project Team
EPAQA
Personnel
EPA Brownfields Project
Officer/ Manager
State Brownfields
Project Manager
Brownfields
Grant Recipient
Quality Assurance
Manager
Environmental Contractor
Project Manager
On-Site Safety Officer
r
T
Project Scientist
or Engineer
Field Team
Leader
Procurement and
Administrative Personnel
T
Project Chemist
I
Database
Manager
KEY
QEPA
O State
O Grant Recipient O Subcontractors
(3 Environmental
Contractor
Subcontractors
Drilling Services Manager
Specialty Field Services Provider Managers
Laboratory Project Manager
Page 4 of 20
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Brownfields Grant Recipients' Road Map to Understanding Quality Assurance Project Plans
Note: The environmental contractor's team composition will differ for a site cleanup
effort, particularly in the type and number of personnel disciplines and subcontractor
service areas.
Table 1 describes the various responsibilities and project roles of environmental
contractor personnel in relation to QAPP development, site assessment and
project reporting.
Table 1-Typical Environmental Contractor's Team Roles and Responsibilities
Responsibilities
Project
Manager
Procurement
and
Administrative
Personnel
Quality
Assurance
Manager
On-site Safety
Officer
Project
Scientist or
Engineer
Field Team
Leader
Project
Chemist
Database
Manager
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Responsible for project planning, execution and quality of performance.
Coordinates with the Recipient and supports technical discussions with the EPA
Brownfields project officer, state regulatory agencies, members of the contractor
project team and other site decision-makers. Manages and provides technical
oversight during QAPP development, field data collection and reporting efforts.
Reports to corporate Principal-in-Charge of grantee's contract and task order.
Supports the review, negotiation and execution of the recipient's contract and
task orders. Provides services for the competitive solicitation, evaluation and
award of subcontracts to drillers, specialty field services providers and analytical
laboratories. Administers invoices to Recipient and issues payments for approved
services performed by subcontractors. Reports to corporate management.
Responsible independent review of all project activities and deliverables and
supporting the resolution of any identified QA issues. Has authority to suspend
project activities if quality requirements are not being met. Reports to corporate
management. All project personnel are required to be responsive to the QA
Manager's input, guidance and directives as related to assuring project quality.
Helps develop the QAPP health and safety plan (HASP). Responsible for field
team's HASP compliance and implementing appropriate site control measures
and personal protection levels based on identified potential site hazards.
Conducts safety briefings for all field personnel and site visitors. Can suspend
operations that threaten health and safety. Reports to corporate health and
safety management.
Helps design and develop the generic QAPP and SAP portion of site-specific
QAPPs and QAPP addendums, including the site assessment strategy and the
numbers, types and locations of samples and specialty measurements. Helps
project team and site decision-makers understand site issues that affect decision-
making^
Responsible for directing day-to-day field activities during site assessment.
Verifies that field sampling and measurement procedures comply with all QAPP
field-related requirements. Provides project manager with regular reports on
status of field activities and notifies of any deviations from the QAPP.
Helps define analytical requirements for generic QAPPs and SAP portion of site-
specific QAPPs and site-specific QAPP addendums. Coordinates with
subcontractor laboratory project manager on analytical requirements, delivery
schedules and logistics, data validation and evaluation and project reporting
efforts.
Responsible for capturing, storing and managing project data. Ensures the flow of
project data in formats that meet the requirements specified in the generic
QAPP, site-specific QAPP or site-specific QAPP addendum. Advises the project
team on the proper database methods for entering, managing and reporting
data.
PageS of 20
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Many Brownfields sites are
addressed under state
cleanup programs. Each of
these programs may have
specific requirements that
can affect the QAPP and site
work, including:
- Action levels for future
uses
- Sampling and analytical
method requirements
Processes for gaining
approval to use
innovative strategies
and technologies
Data evaluation
requirements
Training and
certification
requirements
Document contents and
formats
Brownfields Grant Recipients' Road Map to Understanding Quality Assurance Project Plans
Subcontractor
Driller and
Specialty Field
Services
Provider
Managers
Subcontractor
Laboratory
Project
Manager
Responsibilities
Review SAP portion of site-specific QAPPs and site-specific QAPP addendums to
understand project drilling, sampling and specialty field service requirements,
respectively. Work with the field team leader to ensure successful delivery of
services; including securing utility clearances and property access approvals for
sampling and measurement efforts. Work with the project scientist/engineer to
ensure provision of required data deliverables, both manual and electronic.
Reviews site-specific QAPPs and site-specific QAPP addendums to understand
project analytical methods and related quality requirements. Works with the
project chemist to confirm analytical requirements, delivery schedules, project
reporting and, as necessary, data quality assessments and resolutions.
Note: The above roles and responsibilities are subject to change as a function of any
future revisions to EPA QAPP guidance.
Depending on project and site complexity, it may be beneficial for the Recipient
and its contractor to meet with the EPA and state Brownfields and QA personnel
who can provide input on the technical requirements that will apply to the
Recipient's Brownfields program or site(s). This interaction may occur through
one or several meetings where QAPP development and other matters related to
site assessment and potential remediation are discussed.
To comply with federal funding guidance, recipients must competitively procure
the services of any environmental contractors they hire, who in turn
competitively procure the services of subcontract drillers, specialty field services
providers and laboratories. Procuring environmental contractor support is
generally accomplished by issuing a request for proposal (RFP), reviewing
proposals and selecting the most capable and responsive parties. The RFP for
services must clearly describe the statement of the work for the project,
specifically, the tasks, responsibilities, schedule (particularly if driven by
Brownfields grant funding), deliverables and level of quality the environmental
contractor and its subcontractors are expected to achieve. The RFP contains site
background information, if available, and references federal, state or local
requirements (for example, laws, special training and document formats) that
will apply. If not familiar with these requirements, recipients should minimally
require that the environmental contractor and its subcontractors must meet all
applicable federal, state and local training and professional certification
requirements and comply with all applicable laws and regulations, including
those regarding worker and public health and safety.
The RFP typically requires the environmental contractor to provide a technical
approach that describes how project goals and quality requirements will be
achieved. The environmental contractor is then required to illustrate its
qualifications and past performance record using previous project examples,
resumes and references. The RFP also should require the environmental
contractor's subcontracting plan. The RFP should emphasize that the
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Brownfields Grant Recipients' Road Map to Understanding Quality Assurance Project Plans
environmental contractor must prepare complete QAPPs of a level of quality
that will successfully result in EPA and state approval; however, the Recipient
must work with the environmental contractor to help achieve this outcome.
Various EPA and related resources are available to support RFP development and
proposal review through the Brownfields and Land Revitalization website
(www.epa.gov/brownfields/tools/index.htm).
The EPA Brownfields and Land Revitalization Technology Support Center (BTSC)
(www.brownfieldstsc.org) also provides links to procurement-related resources;
as well as access to site-specific technical support (for example, related to
implementing streamlined investigation approaches).
Recipients are advised to communicate with their Regional EPA and state
Brownfields representatives to seek their input on hiring contractors. The
representatives can also provide information on other entities that provide
technical and procurement resources and support under EPA-funded programs.
Finally, communicating with other area Brownfields recipients, checking
references and getting input from state or Regional parties on past project
results will help in evaluating proposals and selecting a qualified environmental
contractor. Once selected, recipients should work with the environmental
contractor to outline project management and communications approaches for
the program and site projects. This information should be incorporated into the
generic QAPP and, as relevant, the site-specific QAPP or site-specific QAPP
addendum. Clear communication plans are critical for projects where innovative
strategies and technologies are planned for use, as they typically require more
frequent and sometimes near real-time data submittals and communications.
Step 2: Develop Data Quality Objectives and Decision Criteria
Having already prepared and included project information in the
Brownfields grant application, recipients likely have a number of
background documents and other information about the site(s)
and surrounding areas. The environmental contractor typically
reviews site information, conducts a more comprehensive
search for site documentation, performs a site walkover and reviews any other
information, including input from the EPA and state representatives, to develop
the site conceptual model (CSM) for the site(s) of concern.
The CSM is a critical prerequisite for developing a site-specific QAPP or site-
specific QAPP addendum because it summarizes what is known, suspected and
unknown about the site. The CSM serves as the foundation to identify site data
gaps that form the basis for questions that need to be answered by site
assessment efforts. The data gaps directly drive the design of the SAP, including
media to be assessed, strategy and methods to be used to complete sampling,
numbers of samples to be collected and measurements made, analytical
Page? of 20
Step 2 Activities
S Develop conceptual site
model (CSM)
•S Identify data gaps
S Develop quality objectives
and criteria (including "if-
then" statements)
S Confirm and document
special training or
certification requirements
•S Identify the documents
and records to be
developed and maintained
•S Obtain stakeholder and
decision-maker input on
these portions of the QAPP
A conceptual site model (CSM)
is a critical project quality
planning tool and should be
developed for every
Brownfields site assessment
project.
-------
The specific information needs
of key site decision makers
must be addressed in the
QAPP.
Brownfields Grant Recipients' Road Map to Understanding Quality Assurance Project Plans
methods, and other factors that provide the basis for developing project and
data quality objectives and decision criteria.
Establishing decision criteria requires the Recipient and project team to work
with decision-makers to identify the specific decisions that need to be made,
identify who can make what type of decision and establish decision rules that
will be applied to the data collected. Decision rules can be documented in a
decision flow chart or as a series of "if-then" statements that link data to be
collected to a decision that needs to be made for the project or site. The
following "if-then" decision rules are provided as examples only, and should not
be interpreted as being appropriate or required statements for all sites:
• //concentrations of contaminant X in the top 6 inches of soil in the
southern portion of the site are below 150 milligrams per kilogram
(mg/kg), then that portion of the site may be developed as a children's
soccer field.
• //concentrations of contaminant X in the top 6 inches of soil in the
southern portion of the site exceed 150 mg/kg, but are less than 500
mg/kg, then that portion of the site may be developed as a golf driving
range.
• //concentrations of contaminant X in the top 6 inches of soil in the
southern portion of the site are above 500 mg/kg, then that portion of
the site may not be developed and must be remediated.
After decision rules have been developed for the site, criteria must be developed
to describe the level of data quality and procedures required to provide a sound
basis for making each decision. For the "if-then" example above, such criteria
might specify that measurements of contaminant X must be accurate to within a
defined percent of the actual concentrations. Obtaining EPA and state input on
acceptable levels of accuracy will ensure the data collected and analyzed are
sufficient to make remedial decisions described by the "if-then" decision rules.
It is particularly important to communicate with state representatives who must
approve the proposed future reuse for the Brownfields site, to ensure the
information needed to support their site-related decision-making will be
collected. These representatives may be assigned to different offices than the
state QA representatives who are responsible for reviewing the QAPP.
The project team determines the field documentation, data deliverables and
formats that must be produced during data collection and reporting to support
decision-making; the QAPP describes these requirements. Certain site objectives,
criteria and documents may be specific to the region and state where the site is
located and the cleanup program that regulates the site (for example, a state
voluntary cleanup program). Therefore, it is critical to ensure that the team
integrates any location- or program-specific requirements. The EPA and state
Brownfields representatives and the environmental contractor should be able to
Page 8 of 20
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Brownfields Grant Recipients' Road Map to Understanding Quality Assurance Project Plans
help recipients plan ahead to avoid missing a requirement that could hinder the
project down the line. Obtaining frequent input from the team and other
stakeholders will also help keep the project on the right track.
Step 3: Develop Draft QAPP
After developing and reaching consensus on the CSM, data gaps,
project and data quality objectives, decision criteria and rules,
the Draft QAPP can be developed. Various components of a Draft
QAPP are typically developed by different members of the
environmental contractor's project team, based on their areas of
expertise and practical experience. (Suggested roles to support each QAPP
component are included in Appendix B.) Because QAPP sections include
significant amounts of detailed information, they need to be technically
consistent. Therefore, an appropriate team member should be assigned the
responsibility of compiling the various sections of the QAPP, developing and
overseeing document production, and implementing a quality review.
During Draft QAPP development, the project team will address three of the four
common QAPP components identified in Figure 1: Data Generation and
Acquisition; Assessment and Oversight; and Data Validation and Usability.
Additional support in addressing each of these components of the QAPP can be
obtained from the appropriate environmental contractor's subcontractors and
the EPA and state QA representatives.
While the environmental contractor is typically relied upon to lead development
of the QAPP, the Recipient remains responsible for the timely submission of a
technically sound QAPP for EPA and state approval. This requires the Recipient
to actively communicate, coordinate and monitor the project team's progress.
Eligible recipients may seek independent technical support to help guide the
development of the QAPP, including the incorporation of innovative strategies
and technologies, from resources such as EPA's BTSC.
Completion of many of the QAPP sections is dependent upon prior completion of
the site assessment strategy and SAP design. Decisions about what media will be
sampled (for example, air, soil, soil gas, groundwater, surface water, sediment,
sludge, asbestos and lead paint), where samples will be collected and what
analytical methods and detection levels will be used, will drive the design of
other components of the QAPP. Effective and efficient development of the QAPP
components, therefore, will require frequent interactions and clear
communications between the environmental contractor project manager, the
project scientist and engineer, the project chemist and decision-makers who are
closely involved in the project.
For example, analytical methods identified in the QAPP will likely require specific
sampling methods (to ensure adequate sample material is collected) and sample
Page 9 of 20
Step 3 Activities
•/ Assign Draft QAPP
components completion
•S Develop Data Acquisition
and Management
approach
S Identify appropriate
Assessment and Oversight
activities to ensure project
quality
•S Complete Data Validation
and Usability components
of the QAPP to describe
how data will be evaluated
before being used for
decision-making
•S As sections are completed,
obtain team and decision-
maker input to minimize
issues that can arise during
Steps 5 and 6
Eligible Brownfields recipients
may seek technical support for
their projects from the EPA's
Brownfields and Land
Revitalization Technology
Support Center (BTSC).
www.brownfieldstsc.ore/
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Step 4 Activities
v' Distribute the Draft QAPP
for internal team review
•S Discuss team input on the
Draft QAPP
•S Revise the Draft QAPP to
address gaps, comments
and inconsistencies, or
changes identified through
the review
•S Prepare the revised Draft
QAPP for submittal to EPA
or state reviewers
Step 5 Activities
S Submit the draft Final
QAPP for review
•S Obtain EPA or state review
input or approval
S Discuss any input with EPA
or the state and revise, as
necessary
•S Submit the revised Final
QAPP for approval, as
necessary
•S Ensure QAPP approval is
obtained before site work
begins
Brownfields Grant Recipients' Road Map to Understanding Quality Assurance Project Plans
handling approaches (to ensure proper sample preservation, holding times and
shipping temperatures). Effective team communications will help ensure that the
quality objectives and criteria previously derived are reflected consistently
throughout the QAPP. Therefore, the lead authors of each QAPP section should
be encouraged to coordinate with the leads of other closely related sections. In
addition, having QAPP development personnel maintain communication with
EPA and state personnel to obtain their input during development will save
valuable time and cost.
Step 4: Review and Revise the QAPP
Review and revision is an important step because it helps to
ensure the QAPP meets the Recipient's project needs and is
ready for EPA and state review. A high-quality QAPP also
increases the potential for securing EPA and state approval.
The review process typically starts with an internal technical review performed
by senior environmental contractor personnel. In many contractor organizations,
the document will also undergo an editorial review. The completed Draft QAPP is
then submitted to the Recipient for review.
Upon receipt, the Recipient distributes the document to their support personnel
for review. The Recipient compiles all reviewer edits and comments and provides
them to the environmental contractor. The environmental contractor then
revises the QAPP to respond to the Recipient's review, seeking clarification
where needed to ensure appropriate revisions are made. The draft Final QAPP is
then submitted to the Recipient, EPA, state and other stakeholders as directed.
Sometimes project teams may come under pressure to meet expedited
deliverable deadlines or mobilize to the field; this can result in a compressed
schedule for review. However, taking the time to thoroughly review the QAPP
helps ensure that all components are complete and consistent. Review also helps
avoid costly document revisions and schedule impacts during field efforts (if a
significant error was overlooked). For example, if the subcontractor laboratory
provides the incorrect sample bottles or sample preservatives due to an error in
the QAPP, the field team could work with the laboratory to obtain the correct
sample containers and, as necessary, re-sample the site; however, this would
increase shipping and labor costs and a probably cause a delay that could have a
significant impact on the project schedule and any dependent activities. A robust
QAPP review helps to identify and address such potential issues before field
work begins.
Step 5: Submit QAPP for EPA and State Approval
After the Draft QAPP has undergone all necessary reviews and
revisions, a draft Final version is submitted to the EPA and state
Brownfields QA representatives for review and approval. It may
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Brownfields Grant Recipients' Road Map to Understanding Quality Assurance Project Plans
also be necessary to submit the document to other state agencies and
stakeholders who have partial approval authority or significant interest in the
proposed future reuse of the Brownfields site. If input has been obtained from
all important parties throughout the development process, the QAPP will likely
meet their QA expectations and incur only minor comments or input. The
Recipient and the environmental consultant then discuss any input with the
reviewers as needed, revise the QAPP to address their input and submit the
revised Final QAPP to obtain formal approval to initiate field work. The Recipient
should confirm with each reviewing party their specific turnaround times for
review and incorporate these into the overall project schedule.
Step 6: Implement, Monitor and Document Progress
After obtaining QAPP approval, the project team uses it to guide
the Brownfields site assessment project. Although situations in
the field may require intentional deviations from the QAPPs,
such deviations need to be carefully planned and documented
along with any unexpected deviations. Significant deviations may warrant
revising the site-specific QAPP or site-specific QAPP addendum. Discussions with
EPA and state counterparts will help the team identify when such actions are
appropriate. Substantive revisions may require the Recipient to repeat some or
all of the process described in Steps 2 through 5.
Still Have Questions?
The best points of contact for further questions will be the Recipient's Regional
EPA Brownfields project officer and EPA and state QA representatives. These
personnel can provide guidance and assistance in developing and implementing
QAPPs for Brownfields programs and projects. Regional Brownfields
Coordinators (www.epa.gov/brownfields/corcntct.htm) can also provide useful
information and support. Convenient access to the EPA's Regional QA technical
resources webpages is provided on page 12.
References
The following references provide additional information on the Brownfields
Program, general QAPP development, EPA Regional QA and hiring contractors.
General Brownfields Program Information
EPA. 2012. Office of Superfund Remediation and Technology Innovation (OSRTI)
Brownfields and Land Revitalization Technology Support Center (BTSC).
Brownfields Road Map to Understanding Options for Site Investigation and
Cleanup, Fifth Edition: EPA 542-R-12-001. February.
www.brownfieldstsc.org/roadmap
Page 11 of 20
Step 6 Activities
•S Distribute the approved
Final QAPP to project team
S Support communication
and monitor progress
•S Discuss any deviations
required and whether
QAPP revision is warranted
S Obtain approval for any
QAPP revisions
•/ Document QAPP
implementation and
project outcomes
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Brownfields Grant Recipients' Road Map to Understanding Quality Assurance Project Plans
General Quality Assurance Project Plan Guidance
EPA. Office of Environmental Information (OEI) Quality Web Site:
www.epa.gov/QUALITY/qapps.html
EPA. 2008. OEI. U.S. Environmental Protection Agency Quality Policy. EPA
Classification Number CIO 2106.0. CIO Transmittal Number 09-001. October.
www.epa.gov/irmpoli8/policies/21060.pdf
EPA. 2006. OEI. Guidance on Systematic Planning Using the Data Quality
Objectives Process: EPAQA/G-4. EPA 20-B-06-001. February.
www.epa.gov/quality/qs-docs/g4-final.pdf
EPA. 2002. OEI. Guidance for Quality Assurance Project Plans: EPA QA/G-5. EPA
240-R-02-009. December, www.epa.gov/quality/qs-docs/g5-final.pdf
EPA. 2002. OEI. Guidance on Choosing a Sampling Design for Environmental Data
Collection (for Use in Developing a QAPP): EPA QA/G-5S. EPA 240-R-02-005.
December, www.epa.gov/quality/qs-docs/g5s-final.pdf
EPA. 2001. OEI. Requirements for Quality Assurance Project Plans: EPA QA/R-5.
EPA 240-B-01-003. March. (Reissue Notice: May 31, 2006).
www.epa.gov/quality/qs-docs/r5-final.pdf
EPA. 2000. OEI. Quality Manual for Environmental Programs (formerly 5360 Al).
May 5. www.epa.gov/irmpoli8/policies/2105P010.pdf
EPA. 1998. Office of Solid Waste and Emergency Response (OSWER). Quality
Assurance Guidance for Conducting Brownfields Site Assessments. EPA 540-
R-98-038. September, www.epa.gov/brownfields/tools/bfqag4.pdf
Intergovernmental Data Quality Task Force (IDQTF). 2004. Uniform Federal Policy
for Quality Assurance Project Plans. Evaluating, Assessing and Documenting
Environmental Data Collection and Use Programs, Part 1, UFP-QAPP
Manual, Final, Version 1, PA: EPA 505-B-04-900A. DoD: DTIC ADA 427785.
July. http://handle.dtic.miI/100.2/ADA427785
Regional Quality Assurance Technical Resources Webpages
Region 1: www.epa.gov/regionl/lab/qa/qualsys.html
Region 2: www.epa.gov/region2/qa/documents.htm
Region 3: www.epa.gov/region3/esc/qa/qapp.htm
Region 4: www.epa.gov/region4/sesd/sesdpub guidance.html
Region 5: www.epa.gov/R5Brownfields/qapp guidance.html
Region 6: www.epa.gov/region6/qa/qatools.htm
Region 7: www.epa.gov/region7/qa/index.htm
Region 8: www.epa.gov/region8/qa/reference.html
Region 9: www.epa.gov/region9/qa/proiplans.html
Region 10: www.epa.gov/regionlO/qmp/document/qmp.htmltfpartl 422
Page 12 of 20
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Brownfields Grant Recipients' Road Map to Understanding Quality Assurance Project Plans
Hiring Contractors and Integrating Streamline Investigation Concepts
EPA. 2005. OSWER. Understanding Procurement for Sampling and Analytical
Services Under a Triad Approach. EPA 542-R-05-022. June.
www.brownfieldstsc.org/pdfs/Procurement.pdf
EPA. 2001. OSWER. Brownfields Technology Primer: Requesting and Evaluating
Proposals that Encourage Innovative Technologies for Investigation and
Cleanup. EPA 542-R-01-005. February.
www.brownfieldstsc.org/pdfs/rfpfinal.pdf
EPA. 2000. Assessing Contractor Capabilities for Streamlined Site Investigations.
EPA 542-R-00001. January. www.brownfieldstsc.org/pdfs/ContractorCap.pdf
Notice and Disclaimer
This publication was funded by the EPA's Office of Solid Waste and Emergency
Response (OSWER) under EPA Contract EP-W-07-078 to Tetra Tech EM Inc. The
Road Map was produced in collaboration between the Technology Innovation
and Field Services Division (TIFSD) and the Office of Brownfields and Land
Revitalization (OBLR); and supported by Regional Brownfields personnel. Special
appreciation is extended to Nora Conlon (Region 1), Barbara Caprita (Region 4)
and Jan Pels (Region 5) for their review and input. The Road Map was subjected
to the Agency's administrative and expert review and approved for release.
The Road Map provides introductory information rather than guidance and does
not impose legally binding requirements, confer legal rights, impose legal
obligations, implement any statutory or regulatory provisions, or change or
substitute for any statutory or regulatory provisions. The EPA recommends users
refer to applicable regulations, policies and guidance documents regarding
development of QAPPs for Brownfields site assessment and cleanup projects.
The Road Map can be obtained from the EPA's Brownfields and Land
Revitalization Technology Support Center (BTSC) at www.brownfieldstsc.org.
For further information on OBLR, please contact:
• Rachel Lentz of the EPA's OBLR, at (202) 566-2745 or by e-mail at
lentz.rachel@epa.gov.
For further information on BTSC, please contact:
• Carlos Pachon of the EPA's Office of Superfund Remediation and
Technology Innovation (OSRTI), BTSC, at 703-603-9904 or by e-mail at
pachon.carlos@epa.gov.
For region-specific questions regarding QAPPs, please refer to the information
provided for each Region on page 12 of this document.
Page 13 of 20
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Brownfields Grant Recipients' Road Map to Understanding Quality Assurance Project Plans
Appendix A - General QAPP Completion Checklist
Recipients can use this checklist to keep track of their generic QAPP, site-specific QAPP and site-
specific QAPP addendum development efforts.
NOTE: Recipient's should confirm specific QAPP development requirements and processes with
their Regional EPA and state Brownfields representatives.
Project
Name: Location:
Recipient Organization
Name: Date:_
Recipient Project Manager
Name: Telephone: E-mail:
Recipient Quality Assurance Representative
Name: Telephone: E-mail:_
EPA Brownfields Project Officer
Name: Telephone: E-mail:_
EPA Quality Assurance Representative
Name: Telephone: E-mail:_
State Brownfields Project Manager
Name: Telephone: E-mail:_
State Quality Assurance Representative
Name: Telephone: E-mail:_
Environmental Contractor Project Manager
Name: Telephone: E-mail:_
Environmental Contractor Quality Assurance Manager
Name: Telephone: E-mail:_
Prepare for QAPP Development Effort
Dl have reviewed the Brownfields Recipients' Road Map to Understanding Quality Assurance Project
Plans and contacted the EPA Brownfields project officer to obtain appropriate QA representative
contacts.
Page 14 of 20 - Appendix A - General QAPP Completion Checklist
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D
D
Brownfields Grant Recipients' Road Map to Understanding Quality Assurance Project Plans
I have contacted EPA and state Quality Assurance (QA) representatives to confirm the specific QA
procedures and requirements for my location and to obtain their input on:
D
The appropriate QAPP scale and format for my Brownfields program and specific site(s).
Available training or resources (QAPP examples, QAPP templates, guidance, requirements,
checklists and experts).
D
Guidance or suggestions on preparing a Request for Proposal (RFP) to obtain contractor and
laboratory support.
Any special certifications or training that will be needed in our area and for my site work.
Any unique roles and responsibilities that must be included in QAPPs for Brownfields sites in
my specific EPA region and state.
I have reviewed the information provided to me by the EPA and state QA representatives and
forwarded relevant information to other project participants for their use.
Step 1: Establish Project Team
I have communicated with EPA, state and other representatives to seek their input on hiring an
environmental contractor.
I have developed and released an RFP according to my organization's requirements to solicit
proposals for an environmental contractor to support my project.
I have reviewed contractor proposals according to the terms and conditions of my Cooperative
Agreement and my organization's requirements, interviewed the key personnel from the finalists and
selected the preferred contractor.
I have had a preliminary meeting with my EPA Brownfields project officer, my environmental
contractor and the EPA and state QA representatives to discuss my program and site(s) and identify
considerations relevant to the generic QAPP and site-specific QAPP addendum(s) for my site(s).
The environmental contractor has developed a detailed project description that identifies defined
tasks, schedules and personnel roles and responsibilities.
Step 2: Develop Data Quality Objectives and Decision Criteria
The environmental contractor has developed and documented a process for conducting site
assessments within the context of the Brownfields program for inclusion in the generic QAPP.
The environmental contractor has reviewed existing site documentation, developed the conceptual
site model (CSM) for the site and identified key data gaps for the site-specific QAPP or site-specific
QAPP addendum.
Appendix A - QAPP Completion Checklist - Page 15 of 20
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Brownfields Grant Recipients' Road Map to Understanding Quality Assurance Project Plans
D
D
D
D
D
D
The environmental contractor has developed project and data quality objectives and decision criteria.
I have worked with the environmental contractor and decision-makers to (1) refine a list of decisions
to be made and (2) develop specific decision rules to guide our work.
The project team has addressed special training and certification requirements.
The project documentation and data deliverables that will be prepared and maintained (including
consideration of program- or location-specific documentation requirements) have been identified for
inclusion in the QAPP.
I have obtained all required stakeholder and decision-maker input on the decision-dependent
components of the QAPP.
Step 3: Develop Draft QAPP
The environmental contractor has assigned all of the Draft QAPP components to the appropriate
project team members, including the role of compiling each QAPP component into a single
deliverable. Strong team communications and collaboration have been encouraged.
A schedule for completing each element and the compiled Draft QAPP has been established.
The project team has addressed the Data and Acquisition and Management section of the Draft
QAPP, including the site assessment approach and field sampling plan design.
The project team has addressed the assessment and oversight section of the Draft QAPP, including
identification of activities to be implemented to ensure quality.
The project team has addressed the Data Validation and Usability section of the Draft QAPP,
including identification of activities to be implemented to ensure that the data obtained are of
adequate quantity and acceptable quality to support site decision-making.
Step 4: Review and Revise the QAPP
The environmental contractor has performed internal technical review of the Draft QAPP, performed
needed revisions and submitted a final version to me for review.
I have distributed the Draft QAPP to other personnel in my organization for review, as applicable.
I have obtained internal team input on the Draft QAPP and provided a combined set of edits and
comments to the environmental contractor.
Page 16 of 20 - Appendix A - General QAPP Completion Checklist
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D
D
D
D
D
D
Brownfields Grant Recipients' Road Map to Understanding Quality Assurance Project Plans
I have met with the environmental contractor to clarify any questions on my organization's edits and
comments. We discussed the best way to address the reviewer input and I directed the contractor to
proceed with revising the QAPP.
The environmental contractor has revised the Draft QAPP to address gaps, inconsistencies or other
changes identified through my organization's review and finalized it for EPA and state review.
Step 5: Submit QAPP for EPA or State Approval
I have submitted the Draft QAPP to the appropriate EPA and state reviewers, as well as other state
agencies and stakeholders who must approve it before any field activities can be initiated.
As necessary, meetings have been held with QA representatives and the project team to discuss
input, identify necessary actions to address input and enable submission of the draft Final QAPP.
As necessary, the draft Final QAPP has been revised.
As necessary, I have submitted the revised Final QAPP to the EPA and the state for approval.
I have obtained approval on the Final QAPP from appropriate EPA and state representatives.
Step 6: Implement, Monitor and Document Progress
I have provided a copy of the QAPP to all project team members and have advised them that any
deviations from the QAPP must be documented and reported according to provisions in the QAPP.
I have communicated with EPA and state representatives any deviations from the QAPP to determine
whether they warrant a QAPP revision or can be documented for inclusion in project reporting.
I have obtained approval for any QAPP revisions, if necessary.
The project team has prepared the site assessment report that presents the results of all of the data
verification and validation activities described in the QAPP. The report also includes key findings,
conclusions and recommendations for any subsequent site assessment or cleanup efforts.
I have ensured that the project team followed the QAPP and overseen documentation of QAPP
implementation and project findings. Deviations from the QAPP have been documented and shared
with the EPA Brownfields Project Officer.
I have monitored progress and communicated regularly with the project team, decision-makers and
other stakeholders.
We have used the site data and QAPP implementation to support sound decision-making at the site.
Appendix A - QAPP Completion Checklist - Page 17 of 20
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Brownfields Grant Recipients Road Map to Understanding Quality Assurance Project Plans
Appendix B -Technical Components for a Site-Specific QAPP or Site-Specific QAPP
Addendum
Component / Subcomponent Description
A. PROJECT MANAGEMENT
Contains elements that describe key team members, roles and responsibilities,
site background, the problem to be addressed and other information related to
project management and communication.
Al. Title and Approval Sheet
Provides the title of the project and specifies whether the document is a generic
QAPP, site-specific QAPP or a site-specific QAPP addendum. Includes the
signatures of all of the key team members and decision-makers whose
approvals are needed to document approval and agreement that the
environmental data will be collected in an appropriate manner.
A2. Table of Contents
Demonstrates that all of the QAPP components are addressed and specifies
where in the QAPP each is located.
A3. Distribution List
Lists all persons who will need to review or use the QAPP.
A4. Project Team Organization
Provides an organization chart that shows the integrated roles, reporting
structure and lines of communication for project team personnel.
AS. Conceptual Site Model
(CSM)
Describes and presents what is known, suspected and unknown about the
Brownfields site. Provides the foundation for identifying site data gaps that form
the basis for questions that need to be answered by site assessment efforts.
May be in written, graphical or electronic format (such as maps or 3-
dimensional visualizations).
A6. Project Description
Describes the general approach that will be used to address the data gaps
identified during CSM-based project planning. Also describes the main tasks and
schedule that will be implemented to complete the project. For example, it
addresses tasks such as obtaining site access, clearing utility locations before
performing intrusive activities, collecting and analyzing samples, reviewing and
interpreting analytical and other site measurement results and preparing
project reports.
A7. Data Quality Objectives and
Criteria
Uses the information provided by the CSM evaluation and identified data gaps
to construct one or more concise "if-then" statements that describe how the
data collected will be used to support site decision-making. Includes a
description of how data will be evaluated for appropriate use in accordance with
precision, accuracy, representativeness, comparability, completeness and
sensitivity (PARCCS) parameters.
AS. Special Training/
Certification
Provides an overview of any special training or certification required to collect
the environmental data. Requires compliance with any state-required
certifications for the organizations involved in collection and reporting of the
environmental data. In addition, it may address any special training that might
be required for proper operation and maintenance (O&M) of the equipment to
be used at the site.
A9. Documents and Records
Describes the general contents and formats of all the documents and records
that will be prepared for the project. In some cases, the necessary documents
may be largely dictated by the cleanup program (for example, voluntary state
cleanup program) that will be used as the basis for designing and implement site
assessment and cleanup.
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Brownfields Grant Recipients' Road Map to Understanding Quality Assurance Project Plans
Component / Subcomponent Description
B. DATA ACQUISITION and
MANAGEMENT
Describes how and where field measurement data will be acquired and how
samples of each environmental media and analyte classification will be
collected, transported, analyzed and recorded.
Bl. Sampling Process Design
Describes sampling locations and nomenclature for identification, the
environmental media to be sampled (for example, soil, groundwater surface
water and sediment) and the types of chemicals that will be analyzed for in each
sample to support project and site decision-making.
B2. Sampling Methods
Lists all sampling methods that will be used to collect samples; for example, soil
and groundwater sampling equipment, the types of containers to be used for
each media's samples and sample preservation methods.
B3. Sample Handling and
Custody
Describes how each type of sample container will be labeled, confirms whether
labeling will occur before crews mobilize to the field or in the field and defines
how each sample will be prepared for transport, transported to the laboratory
and stored by laboratory personnel. Describes sample chain-of-custody
procedures.
B4. Analytical Methods
Specifies the analytical methods to be used based on the chemicals to be
analyzed and the associated media (air, soil, soil gas, groundwater, surface
water, sediment and sludge). Provides reference to the laboratories Quality
Management Plan (QMP), a standard requirement for any QAPP which requires
laboratory analytical services.
B5. Quality Control
Describes the number and types of quality control samples to be collected and
analyzed at the site, for example field and trip blanks, sample splits and
duplicates; and matrix spikes/matrix spike duplicates.
B6. Instrument/ Equipment
Testing, Inspection and
Maintenance
Describes how the major field sampling and laboratory equipment proposed for
the site will be tested, inspected and maintained in a manner to ensure data
generated achieve the specified levels of quality.
B7. Instrument/ Equipment
Calibration and Frequency
Describes how the major field sampling and laboratory equipment proposed for
the site will be properly calibrated at manufacturer's specified frequencies to
ensure high-quality data.
B8. Inspection/ Acceptance of
Supplies and Consumables
Describes how consumables and supplies (such as tubing for collecting water
samples or plastic pipette nozzles in the laboratory) will be inspected before use
to ensure that subgrade materials do not compromise the quality of the samples
or analytical results.
B9. Non-direct Measurements
Specifies the sources of data and information that will be collected from the
literature or from state or local organizations, how these data will be used in the
decisions to be made and how those data will be reviewed to ensure they are of
a quality consistent with their intended uses.
BIO. Data Management
Describes how all data will be managed. For example, it describes how field
logbooks will be maintained, how the laboratory will record the results of each
analysis and how the laboratory will use these records to prepare and present
data to the project manager. It describes the project database software, if
applicable, and provides information on data entry, storage and exporting. Also
describes the formats for providing each type of data to be produced by the
project.
Appendix B - Technical Components for a Site-Specific QAPP or Site-Specific QAPP Addendum - Page 19 of 20
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Brownfields Grant Recipients Road Map to Understanding Quality Assurance Project Plans
Component / Subcomponent Description
C. ASSESSMENT AND
OVERSIGHT
Cl. Assessment and Response
Actions
C2. Reports to Management
D. DATA VALIDATION AND
USABILITY
Dl. Data Review, Verification
and Validation
D2. Validation and Verification
Methods
D3. Reconciliation with User
Requirements
^^^^^^^^^^^^^^^^^^^^^^^^^^•^^^^^^^^^^^^^^^^^^^^^^^^^^B
Describes the types and frequencies of quality assessments that the project
team will conduct to ensure that project quality goals are being met.
Describes assessment and response actions that will be taken when necessary.
For example, an assessment activity might include a daily review of results from
quality control laboratory blank samples by the laboratory PM; an associated
response action may involve reanalysis of the samples from any batch where
the laboratory blank exceeded a specified concentration.
Provides the format and contents of any planned reports to management based
on the response actions described in Cl. It also addresses who will receive and
act on the information.
Describes how data will be evaluated to determine their validity and usability to
support decision-making process for the site.
Specifies the process that will be used to determine whether or not all of the
types and quantities of data specified in the QAPP were actually collected
(verification) and to compare the data that were collected to the quality control
criteria that are specified in the QAPP (validation).
Describes criteria for annotating data from each batch of samples based on the
analytical results for the quality control samples and instrument calibration
requirements. Describes who will conduct data validation, which involves
summarizing and describing the numbers and types of data annotations that
were assigned to various data. Also describes what percentage of the data will
be validated, what level of data validation criteria will be used and how various
levels of non-conformance or conformance will be documented.
Provides a guide for checking the quality of data obtained against the quality
requirements for decision-making and results in statements on whether the
data collected and results derived will allow the stakeholders to make the
required project and site decisions.
Note: The above components and subcomponents are subject to change as a function of any future
revisions to EPA QAPP guidance. In addition, EPA and state requirements should be checked for location-
specific requirements that may impact QAPP contact.
Page 20 of 20 - Appendix B - Technical Components for a Site-Specific QAPP or Site-Specific QAPP Addendum
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