: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
' WASHINGTON, D.C. 20460
JUN72005
OFFICE OF
SOLID WASTE AND EMERGENCY
RESPONSE
MEMORANDUM
SUBJECT: OSWER DIRECTIVE 9272.0-17
Implementation of the Uniform Federal Policy for Quality Assurance Project Plans
(UFP-QAPP) at Federal Facility Hazardous Waste Sites
FROM: Thomas P. Dunn
Deputy Assistant Administrator
TO: Regional Administrators, Regions I-X
PURPOSE:
The purpose of this Directive is to transmit the final Uniform Federal Policy for Quality Assurance
Project Plans (UFP-QAPP), and provide guidance to the Regions on this Policy, as appropriate,
for all data collection at Federal facility hazardous waste sites.
This Policy is the result of the work of the Intergovernmental Data Quality Task Force (IDQTF),
chaired by the Director of the Federal Facilities Restoration and Reuse Office (FFRRO). It reflects
significant input from and review by a wide variety of EPA Headquarters offices, by every EPA
Regional Office, as well as EPA's partners in this endeavor - the Department of Defense (DoD) and
the Department of Energy (DOE).l The Policy is designed to:
1 The IDQTF includes representatives of the following headguarters offices: OSWER (Office of
Superfund Remediation and Technology Innovation, Office of Solid Waste, Federal Facilities Restoration
and Reuse Office), Office of Environmental Information (Quality Staff), and Office of Air and Radiation
(Office of Radiation and Indoor Air). Although all regions participated on some level, active members of
the workgroup came from Regions 1, 2, 3, 5, 6, 7, and 8. In addition, the UFP-QAPP went through two
cycles of comprehensive review by all Regions (both Quality Assurance Managers and Hazardous Waste
Programs). Finally, all of the military components (Navy, Air Force and Army) participated in the
workgroup, as well as representatives from DOE.
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Assure the integration of quality principles in all Federal facility proj ects that require
environmental data collection and use.
• Streamline document preparation, review and approval by:
Encouraging involvement of an appropriate multi-disciplinary project planning team in
the development of the QAPP
Recommending a consistent content and format
Establishing an agreed starting point of minimum QA/QC specifications for
environmental data collection conducted under CERCLA.
Save time and money in project execution by assuring that data of appropriate quality are
collected to make the decisions required by the project
• Assure consistency with Directives of other federal organizations.
BACKGROUND:
In 1997, a report from the EPA Inspector General (Audit Report No. El SKB6-09-004107100132)
examined laboratory data quality at a limited number of Federal facility National Priorities List (NPL)
Superfund sites. An audit report from the DoD Office of Inspector General (OIG Report 97-098,
Laboratory Support Service for Environmental Testing, February 21, 1997) addressed similar issues.
These reports found real or perceived inconsistencies and deficiencies in data quality within and across
government organizations that resulted in greater costs, time delays, and the potential that some site
risks remain unaddressed.
In response to these audit reports related to Federal facilities, at the direction of the Assistant
Administrator for OSWER, the Federal Facilities Restoration and Reuse Office convened the first
meeting of the IDQTF in the fall of 1997. The focus of the IDQTF is to comprehensively address
problems and issues related to the management of environmental data quality at Federal facilities. The
consensus mission of the IDQTF is "To document an intergovernmental quality system beginning with
the hazardous waste programs." Two products implement this stated mission.
The first product of the IDQTF - Uniform Federal Policy for Implementing Environmental
Quality Systems (UFP-QS) implements Section 5 of the national consensus standard Quality
Systems for Environmental Data and Technology Programs (ANSI/ASQ E4) and parallels EPA's
quality system (Policy and Program Requirements for the Mandatory Agency-wide Quality
System, 5350.1.A2, May 2000). The UFP-QS was signed by the three agencies represented on the
IDQTF in January 2003. The second product - The Uniform Federal Policy for Quality
Assurance Project Plans (UFP-QAPP) - implements Section 6 of E4, and was completed by the
IDQTF m July 2004. It has been approved by DoD and is consistent with the QAPP requirements
outlined in Chapter 5 of EPA Order 5360.1 A2, and EPA's Guidance for Quality Assurance
Project Plans (QA/G-5).
Both IDQTF Policies are based on established requirements. The National Technology Transfer and
Advance Act and OMB Circular A-l 19 urge federal departments and agencies to adopt national
consensus standards such as ANSI/ASQ E4 when they are suitable, Federal Acquisition Regulation
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46.202-4 specifically cites ANSI/ASQ E4 as an acceptable higher level contract quality standard. EPA
Order 5360.1 A2 is also based on ANSI/ASQ E4. The Office of the Secretary of Defense is currently
in the concurrence process for a DoD Instruction that will require defense components to adopt the
UFP-QAPP as the basis for future data collection planning and execution. The DoD Instruction is
analogous to an OSWER Directive.
The UFP-QAPP documents were drafted by a subgroup of the IDQTF over the past five years. The
point of departure for the UFP-QAPP Manual and associated workbook was the EPA Region 1
QAPP guidance. The UFP-QAPP consists of four related documents.
• Part 1 - UFP-QAPP Manual provides policy on the preparation and implementation of QAPP
documents. It sets out steps that address how a QAPP should be prepared, approved and
implemented for all environmental data collection projects. It also provides guidance on how to
integrate technical and quality control aspects of a project throughout its life cycle, including
planning, implementation, documentation, assessment and corrective actions.
• Part 2 of the UFP-QAPP provides supplementary materials for use with the UFP-QAPP
Manual:
- Part 2A, "QAPP Workbook," contains recommended worksheets that are designed to assist in
the preparation of QAPPs by addressing specific requirements of the Manual.
- Part 2B, "Quality Assurance/Quality Control (QA/QC) Compendium: Minimum QA/QC
Activities," describes minimum QA/QC specifications recommended for CERCLA
environmental investigations, depending upon the use of the data. These minimum
recommended specifications are designed to facilitate collaboration at sites by promoting a
consistent set of specifications that can be tailored by the project team to meet the quality
objectives of individual projects. These specifications may be supplemented by additional
parameters based on site-specific needs. The basis for these recommended specifications was
extensive information collected from EPA Regions, DoD and DOE on existing written QA/QC
policies and analysis of the value added nature of the potential range of QA/QC specifications.
- Part 2C, "Example QAPPs," provides several sample QAPPs that demonstrate use of the
recommended UFP-QAPP worksheets to prepare a QAPP.
IMPLEMENTATION:
Scope
The documents transmitted with this Directive apply specifically at Federal facilities. The UFP-QAPP
documents also may be considered more broadly for data collection projects conducted under
CERCLA and RCRA. Regions are strongly encouraged to consider the use of the UFP-QAPP for
other purposes.
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The UFP-QAPP is designated for use in Federal facility projects where environmental data are
collected. It has been designed to be applicable for all environmental data collection related to
hazardous waste investigations (e.g., for the purpose of cleanup under the CERCLA program and the
RCRA corrective action program), as well as data collection related to the active management of
hazardous waste generated by RCRA facilities.
For purposes of this Directive, Federal facility projects include all projects for which a Federal agency
(e.g., DoD, DOE) or its components are responsible. It includes all Base Realignment and Closure
Act (BRAC) related projects, and those Formerly Used Defense Sites (FUDS) or Formerly Used
Sites Remedial Action Program (FUSRAP) related projects where the U.S. Army Corps of Engineers
is the lead project manager.
The QA/QC Compendium (Part 2B of the UFP-QAPP) was developed for and should be used for
CERCLA actions. In many cases, the decisions being made under the RCRA Corrective Action
program should be analogous to the decisions of the CERCLA program, and the QA/QC specifications
outlined in the QA/QC Compendium should be suitable for RCRA cleanups, as well as CERCLA.
The EPA Regions are asked to immediately begin implementing as appropriate, the UFP-QAPP
Manual and its associated documents. Regions should consider:
Application of the UFP-QAPP (content, outline, and format) to all new QAPPs and
substantially revised QAPPs.
- Application of the minimum QA/QC specifications to CERCLA actions
Encouragement of the use of the UFP-QAPP tools to facilitate and streamline review of
QAPPs.
Compliance with the UFP-QAPP (form, content, and minimum QA/QC specifications) will be
considered to be adequate conformance with EPA's QA/G-5 and any Regional guidance on the
preparation of QAPPs. The UFP-QAPP supersedes existing Region-specific QAPP guidance for
Federal facility hazardous waste activities. The Regional EPA office remains responsible for ensuring
that the content of the QAPP provides a quality of data suitable to the needs of the specific project for
which it was prepared.
The UFP-QAPP is a voluntary standard that has been approved by the Department of Defense. The
Department of Energy is in the process of considering formal adoption and FFRRO will encourage
other agencies to use the UFP-QAPP. Implementation of the UFP-QAPP is the responsibility of those
Departments upon adoption and is not subject to notices of violation (NOV). Implementation will be
phased in by the other Departments depending on the requirements of procurement actions and other
factors.
FFRRO will be evaluating implementation of the UFP QAPP. Performance evaluation measures and
tools will be transmitted to Regional Superfund and RCRA Division Directors in the near future by the
Director of FFRRO.
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Implementation Assistance:
Several tools have been jointly developed by EPA and DoD to assist in the implementation of the
UFP-QAPP. A training program on the UFP-QAPP has been developed and pilot tested at four EPA
Regions. It will be offered periodically (see the FFRRO Web site for future opportunities). Electronic
worksheets to facilitate preparation of QAPPs based on the UFP-QAPP are available on the FFRRO
Web site http://epa.gov/fedfac/documents/intergov_qual_task_force.htm. as are all the documents
referenced in this Directive.
CONCLUSION:
The UFP-QAPP is the product of an extensive collaborative effort by management and working level
EPA, DoD and DOE personnel. It was created to address the real and perceived inconsistencies and
deficiencies in data quality that result in greater costs, time delays, and the potential for response actions
that result in unaddressed risk. The UFP-QAPP employs a graded approach designed to encourage a
level of detail consistent with the scope and complexity of the project. It is a tool that can be used
cost-effectively for many different projects.
If you have any questions about the UFP-QAPP or its implementation, please contact:
Mike Carter
Federal Facilities Restoration and Reuse Office
703-603-0046
carter.mike@,epa.gov
Attachment
cc w/o attachment: Kim Nelson, OEI
Tom Skinner, OECA
Jeff Holmstead, OAR
Ben Grumbles, OW
Kathy Callahan, Region 2
RS&T Directors
Federal Facilities Leadership Council
Regional QA Managers
Superfund National Program Managers (Regions I-X)
RCRA National Program Managers (Regions I-X)
IDQTF Members
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