Region 4
U.S. Environmental Protection Agency
61 Forsyth Street, SW
Atlanta, Georgia 30303
QUALITY MANAGEMENT PLAN
August 2018
Prepared by:
Liza I. Montalvo
Region 4 Quality Assurance Manager
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EPA Region 4 Quality Management Plan
Approvals for Region 4
Name:
Title:
Signature,
Monlalvo
Assurance Manager
Date
rA//fr
Name: Vickie H. Tellis
Title:	Acting Director, Science and Ecosystem Support Division
Sienatyre
^C-VlXi		 Date g)k)30l8
Name:	Beverly Banister
Title: r\ Director, Air Pesticides and Toxics Management Division
J4			 Date	/"i
inL
Name:	LaKeshia Robertson
Title: .. _	Acting Director. Gulf of Mexico Program	,
Si gniture ^	YJif n Jx \J __
Name:	Carol Monell
Title:	Acting Director, Resource Conservation and Restoration Division
Signature Date Jjp / "7 i/ ^
Name;
Title:
Signa
Name:	Jeaneanne Gettle
Title:	Director, Water Protection Division
Franklin E_ifill
Date_
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Date

u IX
Name;	Kenneth R. Lapierre
Title:	Assistant Regional Administrator
Signature	j
Name:	Larry S. Lincoln
Title: ^	^ Director, Office of External Affairs
Si mature --1J v<-_ ,L I r<~-- V	^ ^ ^ Date ^ j 1 / / &
Name:	Lei f P aimer
Title:	Director, Office of Regional Counsel
Signature
	 Date W/5~// £
Name:	On is "Trey" Glenn, HI
Title:	Reuional Administrator
Signature		 Date X* j i T j | \
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Table of Contents
1.0 INTRODUCTION	8
1.1	Importance of Environmental Data	8
1.2	Essential Definitions	9
2.0 REGIONAL QUALITY ASSURANCE POLICY AND GOALS	10
2.1	Regional QA Policy	10
2.2	Regional Objectives	11
3.0 REGIONAL ORGANIZATION AND OA RESPONSIBILITIES	13
3.1	Regional Program Organization and Functions	13
3.2	Quality Assurance Responsibilities	18
3.2.1	Regional Administrator (RA)	18
3.2.2	Regional Quality Assurance Manager (ROAM) and SESD Quality Staff	18
3.2.3	Regional Managers	20
3.2.4	Quality Assurance Coordinators (QA Coordinators)	20
3.2.5	Regional Project Managers	21
3.2.6	Regional Project Officers/Contracting Officer Representatives	22
3.2.7	Regional Program Technical Staff.	22
3.2.8	Designated Approving Officials	23
3.2.9	Field Quality Coordinators	24
4.0 REGIONAL QUALITY SYSTEM REQUIREMENTS - EXTERNAL ORGANIZATIONS	25
4.1	State, Local, and Tribal Grants	25
4.2	Academic, Hospital, and Non-Profit Grants and Cooperative Agreements	26
4.3	QA Operations for Interagency Agreements	26
4.4	Quality Management Plans for External Organizations	26
4.5	Quality Assurance Project Plans for External Organizations	27
5.0 REGIONAL QUALITY SYSTEM - INTERNAL ORGANIZATIONS	27
5.1	Divisional Quality Management Plans (QMPs)	28
5.2	Internal Data Operations	29
5.3	QA Operations for Contracts	29
6.0 REGIONAL QUALITY SYSTEM COMPONENTS	30
6.1	Data Quality Objectives	30
6.2	Quality Assurance Project Plan Contents	31
6.3	Standard Operating Procedures (SOP)	32
6.3.1	Preparation ofSOPs	32
6.3.2	Standard Operating Procedure Criteria	32
6.4	Data Processing, Verification, and Validation	34
6.5	Data Quality Assessment	35
6.6	Corrective Action	35
6.7	Information Management	35
6.8	Data Quality Act/Information Quality Guidelines	38
7.0 QUALITY SYSTEM ASSESSMENT	39
7.1	Assessment Management	39
7.2	Types of Assessment	40
7.3	Corrective Actions	42
8.0 DOCUMENTS AND RECORDS	43
8.1 Region 4 Records Management System	43
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9.0 QA COMMUNICATION/REPORTING/WORK PLAN	45
9.1	Regional Communication	46
9.2	QA Annual Report and Work Plan	46
9.3	National Meetings	46
9.4	Resources	46
10.0 PEER REVIEW	47
11.0 TRAINING	47
11.1	Training Needs Assessments	48
11.2	Training Records	49
12.0 QUALITY IMPROVEMENT	49
12.1	Divisional/Program QMPs	49
12.2	Management Systems Assessments/Review	49
12.3	Quality AssuranceTraining	50
APPENDIX A REGION 4 ORGANIZATIONAL CHARTS	51
APPENDIX B REGION 4 MAJOR PROGRAM ELEMENTS	62
APPENDIX C REGION 4 QUALITY MANAGEMENT PLAN AND QUALITY ASSURANCE PROJECT PLAN CHECKLISTS	66
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LIST OF ACRONYMS
ANSI-ASQ - American National Standards
Institute-American Society of Quality
APTMD - Air, Pesticides and Toxics
Management Division
CERCLA - Comprehensive Environmental
Response, Compensation and Liability Act
CFR - Code of Federal Regulations
CLP - Contract Laboratory Program
CO - Contracting Officer
CSI - Compliance Sampling Inspection
CWA - Clean Water Act
DAO - Designated Approving Official
DMRQA - Discharge Monitoring Report
Quality Assurance
DQA - Data Quality Act
DQO - Data Quality Objectives
ESAT - Environmental Services Assistance
Team
FAR - Federal Acquisition Regulations
FOIA - Freedom of Information Act
GIS - Geographic Information System
IA - Interagency Agreement
IM - Information Management
IQGs - Information Quality Guidelines
NPL - National Priority List
NPDES - National Pollutant Discharge
Elimination System
NTSD - National Technology Services
Division
OEI - Office of Environmental Information
OPM - Office of Policy and Management
(Region 4)
PAI - Performance Audit Inspection
PE - Performance Evaluation
PO - Project Officer
QA - Quality Assurance
QAS - Quality Assurance Section
QC - Quality Control
QAPP - Quality Assurance Project Plan
QAARWP - Quality Assurance Annual
Report and Work Plan
QAFAP - Quality Assurance Field
Activities Procedure
QMP - Quality Management Plan
RCRD - Resource Conservation and
Restoration Division
RQAM - Regional Quality Assurance
Manager
RA - Regional Administrator
SDWA - Safe Drinking Water Act
SESD - Science and Ecosystem Support
Division
SOP - Standard Operating Procedure
START - Superfund Technical Assistance and
Response Team
USACE - U.S. Army Corps of Engineers
USGS - United States Geological Survey
WPD - Water Protection Division
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1.0 INTRODUCTION
This management plan documents the quality system used in EPA Region 4 as required by EPA CIO
2105.0, "Policy and Program Requirements for the Mandatory Agency-Wide Quality System"
(Formerly EPA Order 5360.1 A2). CIO 2105.0 requires that each EPA Program and Regional Office
develop and document a quality system to assure that environmental data used to support Agency
decisions is of adequate quality and is usable for its intended purpose. This Quality Management Plan
(QMP) describes Region 4's quality system. A quality system is a structured and documented
management system which describes an organization's roles, responsibilities, policies, and procedures
as they relate to the generation and use of environmental data and the implementation of
environmental technology. The plan covers quality assurance policies, roles and responsibilities for
environmental data collection activities. This includes the collection, evaluation, and use of
environmental data produced by regional programs and data generated through extramural
agreements. Extramural Agreements include:
•	Acquisitions including: contracts, work assignments, task orders, technical directives
•	Financial assistance including:
o Cooperative agreements
o Grants to state and local governments
o Research grants
o Grants to non-profit organizations
•	Interagency agreements
In addition, the plan covers environmental technology which is funded by the Agency with a purpose
to prevent pollutants from entering the environment or to remove pollutants from the environment.
This document is intended for use by EPA Region 4 managers and staff, as well as those organizations
producing environmental data under an EPA extramural agreement. The document provides a link
between quality assurance (QA) policy as defined in CIO 2105.0, and the implementation of this
Agency Directive and associated procedure (EPA's Quality Assurance Field Activities Procedure
(QAFAP), CIO 2105-P-02.0, 9/23/2014) in Region 4. It is important to note that this plan does not
cover all Region 4 management systems, but only those which are related to the generation and use of
environmental data and the use of environmental technology.
1.1 Importance of Environmental Data
Environmental data are a critical input to the Agency's decisions to protect human health and
the environment. Most of the decisions which are made in the region concerning the
management of the environment and reduction of risk ultimately require the use of
environmental data which are generated by EPA, or by state, tribal, local government, and/or
private sector organizations. Therefore, it is critically important that decision makers know
the origin and quality of the environmental data used in these decisions. The quality of
environmental data is known when all components associated with its derivation (precision,
bias, completeness, comparability, sensitivity, representativeness, and usability) are
documented.
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1.2 Essential Definitions
1.2.1	Quality System - A structured and documented management system
describing the quality assurance policies, practices, protocols, and procedures for
ensuring that (1) environmental data are of known and documented quality; and, (2)
environmental technology is designed, constructed and operated in a manner to
produce the desired environmental results.
1.2.2	Environmental Data - Information collected directly from measurements,
produced from models, or compiled from other sources such as databases or literature,
which are used for decision making purposes. This data/information may include
existing data.
1.2.3	Internal Data - Data generated by or for Region 4 programs where regional staff
have primary responsibility for project or task decisionmaking. Region 4's quality
assurance system requirements apply to these data.
1.2.4	Extramural Data - Data generated by organizations other than Region 4 which
are funded by EPA through extramural agreements.
1.2.5	Existing Data - any data or information available that was originally collected
for a purpose different from the one for which they are intended to be used. This may
be data or information:
•	collected by the same project team previously for another purpose
•	produced during other environmental investigations
•	produced by the agency or a contractor to EPA
•	produced outside EPA (extramurally),
•	obtained from other document information systems
•	obtained from studies
(See Chapter 3, Projects Using Existing Data, Guidance for Quality Assurance Project
Plans, EPA/240/R-02/009, EPA QA/G-5, December 2002, for additional clarification.)
1.2.6	Environmental Technology - An all-inclusive term used to describe pollution
control devices and systems, waste treatment processes and storage facilities, and site
remediation technologies and associated components that may be utilized to remove
pollutants or contaminants from or prevent them from entering the environment.
Examples include wet scrubbers (air), soil washing (soil), granulated activated carbon
unit (water), and filtration (air, water). Usually, this term applies to hardware-based
systems; however, it also applies to methods or techniques used for pollution
prevention, pollutant reduction, or containment of contamination to prevent further
movement of the contaminants, such as capping, solidification or vitrification, and
biological treatment.
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1.2.7	Quality Assurance (OA) - An integrated system of activities including
planning, implementation and assessment to ensure environmental data are of known
and documented quality, and environmental technology produces the desired results.
1.2.8	Quality Control (PC) - The overall system of technical activities that measure
the performance of a process or item against defined standards to ensure the process or
item meets the pre-defined standards of the customer. Quality control measures also
apply to engineering controls for construction and design activities.
1.2.9	Quality Assurance Project Plan (QAPP) - A critical planning document for a
project, study or task, describing how data collection activities are planned,
implemented, and assessed.
1.2.10	Data Quality Objectives (DQOs) - A systematic planning system designed to
produce qualitative and quantitative statements that clarify project objectives, define the
appropriate type of environmental data, delineate the decision rules, and specify
tolerable levels of decision error.
1.2.11	Graded Approach - The process of selecting the elements needed in a project-
level planning document based on the complexity of the project or study undertaken
and the degree of confidence needed in the environmental data, and the intended use of
the results.
2.0 REGIONAL OTIATJTY ASSURANCE POIJCY and GOALS
2.1 Regional QA Policy
Region 4 is strongly committed to sound science and QA practices which will produce
environmental data of appropriate quality to be used for decision making. This commitment is
consistent with the goals of CIO 2105.0 and associated QAFAP. It is the policy of Region 4
that all decisions which are made to protect human health and safeguard the environment will
be based on data of sufficient known quality to support the level of decision required.
Regional policy also includes a commitment by management that the quality system
supporting the generation of data of known quality and effective environmental technology
will be implemented as described in this plan. The Region 4 policy is achieved by ensuring
adequate and acceptable planning, implementation, and assessment procedures are utilized
through all phases of projects/studies/tasks which require the generation of environmental
data and/or the use of environmental technology.
Regional managers and staff will assure there are sufficient QA activities conducted by the
environmental programs to provide reasonable confidence that all environmental data
generated are scientifically valid; of adequate quality and quantity for the intended use; of
known precision and bias; of acceptable completeness, representativeness, comparability, and
usability; and where appropriate, legally defensible. Environmental data quality is the
responsibility of all EPA Region 4 staff who are directly or indirectly involved in the
collection, production, and use of data. Senior managers in each division will assure adequate
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resources, including personnel, travel funds, and extramural funds, are available to implement
the regional quality assurance system.
To effectively and efficiently utilize resources dedicated to quality assurance activities in
Region 4, division and/or office staff are responsible for conducting a preliminary review of
quality assurance project plans (QAPP) prior to submittal to the SESD, Quality Assurance
Section (QAS) staff for review and Regional Quality Assurance Manager (RQAM) approval.
However, Region 4 divisions may elect to use Designated Approving Officials (DAOs) to
review and approve QAPPs. A division electing to use DAOs must clearly define protocols
for their use in its divisional QMP, and ensure individuals selected to review and approve
QAPPs complete DAO training.
The divisions will designate QA Coordinators. The duties and training requirements of the
Quality Assurance Coordinator are outlined in Section 4.2.8 of this Plan. Their duties will be
clearly defined in their respective Divisional QMP. The requirement for QA Coordinators
must comply with all those defined in this QMP. Presently, QA Coordinators report directly
to their first line supervisor unless otherwise stated in their respective QMPs, but receive
guidance pertaining to Region 4 Q A activities from the RQAM.
In addition, the divisions may designate Field Quality Coordinators (FQCs) responsible for
implementation of the QAFAP. The duties of the FQCs vary by Division and are outlined in
Section 4.2.9 and further defined in the Divisional QMP. The duties of the FQCs are
outlined in Section 4.2.9 of this plan. Their duties will be clearly defined in their respective
Divisional QMP. The requirement for FQCs must comply with all those defined in this
QMP. Presently, FQCs report directly to their first line supervisor unless otherwise stated in
their respective QMPs, but receive guidance pertaining to Region 4 QA activities from the
RQAM.
2.2 Regional Objectives
The following are the regional objectives which serve to support the regional policy:
2.2.1	Regional QA System activities shall comply with, ASQ/ANSI E4-2014,
"Quality Systems for Environmental Data and Technology Programs —
Requirements with Guidance for Use" (ASQ/ANSI E4) with respect to planning,
implementing and assessing quality assurance activities. It is EPA policy that all
environmental programs performed by EPA or for EPA shall be supported by
individual quality systems that comply fully with the ASQ/ANSI E4 specifications. In
addition, all environmental technology constructed for pollution prevention, control,
or waste remediation should be designed, constructed and operated according to pre-
defined specifications. Specific guidance on environmental technology design,
construction, and operation is found in EPA Guidance on Quality Assurance for
Environmental Technology Design, Construction, and Operation, EPA QA/G-11.
2.2.2	The data quality objectives (DQO) process, or a similar systematic planning
process, shall be used to plan project or study goals and objectives as related to
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programmatic or regulatory requirements, and needed environmental data quality
prior to the initiation of data collection activities. The Guidance on Systematic
Planning Using the Data Quality Objectives Process (EPA QA/G-4),
February 2006, provides a standard working tool to develop DQO for determining
the type, quantity, and quality of data needed to reach defensible decisions or make
credible estimates. DQOs, or similar outputs from a systematic planning process,
shall be documented in a QAPP, or equivalent project-level planning document
2.2.3	QAPPs or equivalent planning documents shall be developed by those staff
(either EPA or contractor) responsible for designing and implementing a project,
study, or task which requires the collection or use of environmental data. QAPPs
and equivalent planning documents shall meet the requirements specified in EPA's
Requirement for QAPP, EPA/240/B-01/003, QA/R-5 (February 2006), and will
incorporate project-specific DQOs. QAPPs will be developed using a graded
approach consistent with the complexity of the project and the intended use of the
data.
2.2.4	Extramural organizations which receive EPA extramural funding for
environmental data collection activities, shall have an approved QMP with the
requirements specified in EPA's Requirement for QMPs, EPA/240/B-01/002,
QA/R-2 (March 2001) document. This document must illustrate that a quality system
is in place to ensure all data collection activities are appropriately planned,
implemented, and assessed. If it is determined by the divisions/programs or RQAM
that a QAPP must be provided for a specific data collection activity. Then the
document must comply with the requirements specified in EPA's Requirement for
QAPPs, EPA/240/B-01/003, QA/R-5 (February 2006) document consistent with a
graded approach. The Region has the authority to conduct oversight of organizations
or their sub-organizations, and the authority to require corrective actions of both
organizations in the event the Regional QA policies or objectives were not met.
2.2.5	Regional managers and staff shall receive QA training appropriate for
their responsibilities related to data collection or environmental technology.
2.2.6	Communication on QA issues and activities shall be maintained between the
RQAM, Regional Senior Management as appropriate, as well as with program
managers, quality assurance coordinators, and staff.
2.2.7	Assessments shall be performed to determine the effectiveness of
Regional and extramural quality systems.
2.2.8	QA processes shall be designed in the most resource-effective manner without
compromising data quality. Continuous improvement in the quality management
system shall be emphasized.
2.2.9	Projects using existing data will follow the guidance in
EPA/240/R-02/009, EPA QA/G5.
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3.0
REGTONAT, ORGANIZATION and OA RFSPONSTBTT TTTES
3.1 Regional Program Organization and Functions
Region 4's organizational structure is shown in Appendix A, pages 51 - 61. Major program
elements and activities are shown in Appendix B, pages 62-65. The role of each regional
program organizational unit covered by the QA requirements is briefly described below:
3.1.1 Science and Ecosystem Support Division (SESD)
The Division manages the regional quality system. The RQAM resides at SESD and is
supported by SESD QATSB/QAS personnel.
This Division is one of the primary organizations within Region 4 that collects and
produces environmental data. It conducts field investigations, inspections, projects,
studies and assessments which often require sampling of environmental media. SESD
also analyzes multi-media environmental samples; processes and evaluates multi-media
environmental data; and prepares projector study reports which summarize results
and/or provide conclusions and recommendations. All field and analytical activities are
undertaken at the request of the regional program divisions under memoranda of
agreement and work plans negotiated annually between SESD and the program
divisions. Additional special projects may be requested by the Regional Administrator
or other organizations. SESD performs specific QA assessments of selected external
environmental monitoring projects as requested by the program divisions.
The SESD quality system encompasses all divisional QA related activities; field
investigations, measurement and sampling; laboratory analyses; and management of
the Regional QA Program. Within SESD, there are two (2) branches that generate
environmental data and/or compliance monitoring data for the regional programs:
Field Services Branch (FSB) and Analytical Services Branch (ASB). The Quality
Assurance and Technical Services Branch (QATSB) personnel provides QA
assistance to the regional programs including QMP and QAPP reviews, Contract
Laboratory Program (CLP) data validations, etc. In addition, SESD maintains
accreditation under ISO 17025, General Requirements for the Competence of Testing
and Calibration Laboratories for both field and laboratory operations under one scope of
accreditation.
The Agency's Science Policy Council's issued a directive on February 23,2004, entitled
"Assuring and Documenting the Competency of Agency Laboratories". The directive
required all laboratories to maintain competency by documenting and maintaining a
quality system which meets the requirements of CIO 2105.0, Policy and Program
Requirements for the Mandatory Agency-Wide Quality System, May 2000. To
demonstrate competency, the policy required EPA laboratories to (1) have periodic
external assessments, (2) participate in an appropriate, recognized laboratory
accreditation program when available, and, (3) participate in inter-laboratory
comparison studies/programs. The SESD laboratory continues to meet the requirements
of the Laboratory Competency Policy by maintaining its accreditation under ISO 17025.
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The laboratory's quality system is documented in a QMP entitled "Analytical Support
Branch Laboratory Operations and Quality Control Manual" dated April 24, 2017.
3.1.2	Air. Pesticides & Toxics Management Division (APTMD)
The Division manages the program for and implements the Clean Air Act (CAA);
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA); and the Toxic
Substances Control Act (TSCA), except for TSCA Polychlorinated Biphenyls (PCB)
managed by the Resource Conservation and Restoration Division (RCRD). APTMD
also serves as the technical/program authority for all monitoring activities associated
with these programs. It ensures that QA matters are reflected in budgets, program plans,
and work/operating plans. The Division manages grants, contract funds, and
cooperative agreements, and overviews external environmental monitoring programs
which require the collection of environmental data. SESD provides the APTMD with
technical assistance relevant to monitoring and data processing activities, including
QA oversight.
3.1.3	Superfund Division
The Division manages the program for and implements the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA) and the Oil
Pollution Act (OPA) of 1990, including Emergency Response Programs. It manages
federal grants and contract funds. The Division ensures QA matters are properly
reflected in budgets, program plans, and work/operating plans. It serves as
technical/program authority for all hazardous waste environmental monitoring
activities within the geographical boundaries of Region 4. The data arising from these
programs are the product of efforts both internal and external to the Region. The
Division provides oversight for external environmental monitoring programs which
require the collection of environmental data. SESD provides the Superfund Division
with technical assistance relevant to the collection of environmental data, including QA
oversight. This includes regional management of the CLP, data validation of CLP
analytical data and regional contract laboratory data, management of the Environmental
Services Assistance Team (ESAT) contract, systems audits of state field and laboratory
activities, and overview of potentially responsible parties' remedial actions at CERCLA
sites.
3.1.4	Resource Conservation and Restoration Division (RCRD)
The Division recommends goals, priorities, and objectives for the Resource
Conservation and Recovery Act (RCRA), the Oil Pollution Act (OPA) of 1990, and the
Small Business Liability Relief and Brownfields Revitalization Act programs to the
Region 4 Regional Administrator, the Office of Land and Emergency Management
(OLEM) and the Office of Enforcement and Compliance Assurance (OECA). Major
program areas include RCRA Enforcement and Compliance, OPA Enforcement,
RCRA Corrective Action, RCRA Permitting, Underground Storage Tanks,
Brownfields, Solid Waste Management, Materials Management and the National
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Environmental Policy Act (NEPA). It assists the States in developing comprehensive
programs within delegated or related program areas including providing or arranging
for technical assistance to state and local agencies in developing necessary plans,
monitoring systems, instrumentation, data collection and analysis systems, and
emergency response, including imminent hazards. The Division represents the Region
in carrying out the implementation of programs for which it is responsible. The
Division is comprised of three branches: Enforcement and Compliance; RCRA
Cleanup and Brownfield; and Materials and Waste Management, and the NEPA
Office.
SESD provides the RCRD with technical assistance for monitoring and data collection
and interpretation activities, including QA oversight. Also, SESD conducts
Comprehensive Groundwater Monitoring Evaluations and Compliance Enforcement
Investigations at RCRA facilities, provides technical assistance and training to
States/Indian Tribes/Region 4 RCRA program personnel and conducts system audits of
state field and laboratory activities.
3.1.5	Water Protection Division (WPP)
This Division has the program and implementation responsibilities for the Safe
Drinking Water Act (SDWA), Clean Water Act (CWA), ambient surface water and
groundwater, underground injection control, estuarine waters, off-shore discharge, and
domestic and industrial wastewater treatment programs. It is responsible for oversight
of delegated permitting and compliance as well as the delegated enforcement for
municipal and industrial wastewater treatment facilities. The Division manages federal
grants and contract funds. It ensures QA matters are properly reflected in budgets,
program plans, work/operating plans. WPD serves as the technical/program authority
for all water-related environmental monitoring activities within the geographical
boundaries of Region 4. The data arising from these programs are the product of efforts
both internal and external to the Region. The Division provides oversight for external
environmental monitoring programs which require the collection of environmental
data. SESD provides the WPD with technical assistance relevant to monitoring and
data collection and interpretation activities, including QA oversight. This includes
oversight of State/Tribal/Local fixed, ambient water monitoring networks' special
ambient water studies' performance audits on water and wastewater field monitoring
and laboratory operations' National Pollutant Discharge Elimination System (NPDES)
compliance inspections and oversight inspections; and systems audits of state field and
laboratory activities.
3.1.6	Office of Enforcement Coordination (OEC)
This Office has the overall planning, accountability and coordinating responsibilities
for enforcing the various environmental statutes which the Region implements. These
responsibilities include: (1) integrating compliance assurance activities to facilitate
multi-media projects at the Regional and State/Tribal/Local levels; (2) performing the
planning and targeting necessary for the Region's compliance assurance plan; (3)
assisting the media programs in developing strategies and tools for assisting the
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regulated community in achieving compliance with Agency statutes; (4) supporting the
environmental compliance activities on Tribal lands; and (5) coordinating with our
State counterparts on environmental enforcement issues.
The activities of the OEC do not normally require monitoring or measurement
activities which involve data collection.
3.1.7	Office of Policy and Management (OPM)
This Division administers human resources management, budget and finance,
procurement and grants administration, information management, and planning and
analysis.
Within OPM's Facilities, Grants & Acquisitions Management Branch (FGAMB), the
Grants and Audit Management Section manages the business aspects of grants
administration. This includes the award and administration of funded projects (from
project initiation through final close-out).
Within the FGAMB, the Acquisitions Management Section contracts for goods and
services. Implementation of quality standards for contracts is defined in CIO 2105.0,
as well as the EPA Acquisition Guide.
OPM's Information Systems and Management Branch develops and implements
policies and guidance to ensure information management (IM) resources are
efficiently, economically and effectively utilized throughout the Region. The Branch
reviews and approves requests for IM acquisitions and services to ensure conformity
with policy directives and specifications. This organization also provides management
and operational support for the integration of environmental data into Geographic
Information Systems (GIS). GIS are software and hardware systems used by media
programs and support organizations to more efficiently and accurately analyze and
interpret environmental data. While the Environmental Information Services Branch
does not generate environmental data, it cooperates with the appropriate media
program to assure that the data used in GIS, computer models and databases are
suitable for their intended use.
SESD provides OPM with technical assistance by reviewing QAPPs, QMPs, and
contract Scopes of Work.
3.1.8	Gulf of Mexico Program
The Gulf of Mexico Program (GMP), initiated in 1988, is a non-regulatory program.
Organizationally, the program falls within the Region 4 management structure. The
program was developed because no single agency or level of government had either the
necessary technical or financial resources or the legal mandate to address the spectrum
of environmental and public health issues facing the Gulf. The Gulf Program is a
collaborative effort including a consortium of stakeholders sharing significant interests
in coastal and marine resources. The GMP's ecosystem-based approach brings the
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appropriate science, together with the financial and technical resources, to help the
Gulf States and coastal communities address their environmental problems within a
broader regional and national context.
The GMP leads federal research, monitoring, scientific analysis, and financial
resources supporting state and community actions that benefit the Gulf and its
communities. The GMP engages in activities such as monitoring water quality in
watersheds that flow into the Gulf. Staff are involved in managing grants and
interagency agreements, providing technical/scientific support to stakeholders within
the Gulf region, and coordinating/conducting scientific studies to achieve common
goals. Environmental data are collected in partnership with Gulf communities to assess
and solve environmental issues in the community.
SESD provides GMP with technical assistance, as appropriate, by reviewing QAPPs,
QMPs, and contract Scopes of Work. GMP has certified DAOs to approve QAPPs and
works with EPA Region 4, EPA Region 6, and other appropriate EPA locations to
ensure required partner QA documents are approved. GMP's work with partners as a
geographic great water body program naturally occurs in multiple EPA regions that
make up the Gulf of Mexico watershed. GMP defers as much as possible to R6's QMP
for consistency when working with entities in Louisiana and Texas (this helps GMP
partners in those states have consistency in their QMP/QAPP development and
expectations as they normally work through R6). GMP currently uses the R4 QMP as
the GMP QMP. Because many of GMPs funded projects collect a minimal amount of
environmental data, QAPPs and QMPs are developed using a graded approach
consistent with the complexity of the project and the intended use of the data.
3.1.9 Office of Environmental Justice and Sustainabilitv
The Office of Environmental Justice and Sustainability (OEJS) is located in the Office
of the Regional Administrator. OEJS works collaboratively with the Headquarters,
Office of Environmental Justice, internal and external stakeholders to address public
health issues and concerns in minority, low-income, tribal and other vulnerable
communities through the EPA Environmental Justice (EJ) Collaborative Problem-
Solving Grants Program and the EJ Small Grants Program. Both programs provide
financial assistance to assist communities develop and implement solutions to
significantly address environmental and/or public health issues at the local level.
Historically, resources from these programs consist of grant awards up to $120,000
through the EJ Collaborative Problem-Solving Grants Program and up to $30,000
through the EJ Small Grants Program. Additional resources include technical
assistance, mapping tools and training materials.
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3.2 Quality Assurance Responsibilities
Regional managers and staff have the following responsibilities for the quality system:
3.2.1	Regional Administrator (RA)
The RA has the overall responsibility for the development, implementation, and continued
operation of the Regional QA Program. The authority for managing the day-to-day QA
activities within the Region is delegated to the Regional Quality Assurance Manager.
3.2.2	Regional Quality Assurance Manager (ROAM) and SESD Quality Staff
The RQAM was delegated oversight of the Region 4 Quality System. The RQAM,
administratively reports to SESD's QATSB Chief and is independent of any data generation
activities within SESD or the Region. The RQAM serves the official Regional contact for all
QA matters within Region 4 by providing advice, guidance, assistance and training as needed
or requested by regional managers and staff. Specifically, the RQAM:
•	Facilitates development of the Region's QMP and prepares updates to the approved
QMP;
•	Represents the Region at national quality meetings, such as the RQAM monthly
conference call, national QA conferences, etc. Also, serves as primary Regional
Liaison with the Office of Environmental Information (OEI), Environmental Quality
Management Division (OEI EQMD);
•	Provides expert assistance to regional staff on QA/QC policies, requirements, and
procedures applicable to technical activities/services;
•	Provides, schedules and/or notifies Regional staff of required QA training;
•	Advises staff on development of QAPPs for internal data. This may include
explanation of and/or review of the data quality objective process. The RQAM will not
review a QAPP in which he/she has assisted in its development, but will delegate the
review to another staff member.
•	Reviews and approves QAPPs for internal and external Regional data operations.
•	Reviews and approves QMPs submitted by Region 4 Divisions and Offices and by
holders of extramural agreements;
•	Oversees Regions 4's field quality management system for compliance with EPA's
QAFAP, CIO 2105-P-02.0, 9/23/2014;
•	Performs periodic assessments of Regional organizations that conduct environmental
data operations to determine the conformance of their mandatory quality systems to
their approved QMPs and applicable standard operating procedures, and the
effectiveness of their implementation;
•	Coordinates and/or conducts system and performance audits of selected environmental
monitoring programs.
•	Coordinates and participates in the OEI EQMD review of the Region 4 quality system;
•	Coordinates and submits the Annual QA Report and Workplan to Region 4 Senior
Management and OEI EQMD;
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•	Distributes Agency QA guidance documents, policies, and procedures;
•	Initiates and/or revises Regional QA policy & procedures; and
•	Briefs senior staff on QA issues on an annual basis or more often as needed.
In addition to the RQAM, SESD QATSB/QAS personnel perform the following functions for
the entire Region:
•	Conduct assessments of State, Tribal and other external partner quality management
systems.
•	Review QMPs and QAPPs and recommend approval status of these plans to the
RQAM.
•	Perform laboratory assessments of state, commercial, tribal, and/or other government
laboratories as required by SDWA, CWA, and CLP. The Region 4 CLP contracting
officer representative (COR) is in SESD QATSB/QAS.
•	Overview of the regional Drinking Water Certification program. The Certification
Authority for the State Primacy Laboratories and Satellite labs is the responsibility of
the Regional Administrator (RA) in the Region. The Region 4 RA has delegated this
authority to the SESD Division Director. The Regional Drinking Water Certification
Officers are in SESD QATSB/QAS.
•	Perform assessments, including management system assessments, data quality audits,
and performance audits.
•	Manage and administer the regional ESAT Contract which includes overview of data
review and validation and other QA activities conducted under this contract.
•	Provide technical and quality assurance training to Region 4 staff and entities external
to EPA.
•	Provide technical assistance/support to the RQAM to meet the requirements addressed
in this QMP.
•	A designated SESD QATSB/QAS staff member serves as the regional Alternate Test
Procedure (ATP) Coordinator for NPDES and Wastewater. Responsible for approving
alternative testing procedures to those procedures required in EPA approved testing
methods. Works in conjunction with the EPA Office of Water staff in this process.
Personnel from the SESD, Field Services Branch, perform QA assessment activities, including
technical system assessments, data quality audits, performance audits, and technical/QA
training for the Clean Air Act, CERCLA, RCRA, and the Clean Water Act.
The RQAM may require suspension of environmental data collection projects and request
corrective action if data quality/environmental technology QA activities do not meet Agency
QA policy or requirements. If the RQAM determines that any regional data collection
activities (at the project or program level) do not meet Agency quality assurance policies or
requirements, the RQAM shall make every effort to resolve disputes through discussion and
negotiation. Disagreements will be resolved at the lowest administrative level possible. Should
agreement not be reached at this level, the RQAM, after briefing the SESD Director, shall
elevate the issue to Senior Management for resolution. The RQAM has the authority to directly
and independently interact and communicate with the Deputy Regional Administrator (DRA)
on all QA matters. This direct access to the DRA allows the RQAM to independently elevate
critical quality-related issues at his/her discretion without challenge. The RQAM does not need
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approval or pre-notification to initiate such communication. The RA/DRA shall have final
dispute authority on all quality issues.
The RQAM utilizes the Regional QA staff including Quality Assurance Section, QA
Coordinators and Field Quality Coordinators to assist in the day-to-day implementation of the
Regional quality system. QA staff has access to appropriate levels of management to address
all QA matters. They will use commonly accepted practices, such as starting with the lowest
possible level of management and escalating to higher levels of management only as
necessary, to resolve conflicts. The QA staff is expected to notify the RQAM whenever any
level of management involvement is needed to resolve QA issues.
3.2.3	Regional Managers
Division/Office Directors ensure that internal and extramural data collection activities within
their programs are conducted in accordance with Agency and Region 4 QA policy. QA
management is the daily responsibility of the appropriate second or first level managers (i.e.,
Branch and Section Chiefs). Within their area, line managers establish procedures in their
Divisional QMP to ensure the acceptability of data and the suitability of environmental
technology. Managers will:
•	Establish planning policies to ensure that appropriate QA procedures are reflected in
budgets, program plans, and operating plans.
•	Encourage the development of Data Quality Objectives (DQO's) for data collection
activities.
•	Require the development of QAPPs or an equivalent project-level planning document
for projects involving data collection.
•	Support regional quality system implementation and assessment.
•	Take corrective action as required by QA assessments or reviews.
•	Report data quality problems to the RQAM. Assure personnel receive appropriate QA
training by working with the RQAM on the development of a training curriculum for
staff. This training curriculum will be included in the Divisions/Offices QMP.
•	Managers and supervisors will be expected to include staff QA training needs in
employee Individual Development Plans. The Learning and Development Institute
(LDI) maintains electronic records of all the training provided by the Institute and this
information is available to both the employee and their manager/supervisor.
•	Ensure that QA responsibilities of the RQAM are included in his/her performance
appraisal system (PARS).
•	Select, monitor and insure appropriate training is provided to Designated Approving
Officials as defined by the RQAM.
3.2.4	Quality Assurance Coordinators (OA Coordinators)
Each Division director will appoint at least one manager or staff person to serve as the QA
Coordinator for his/her Division. QA Coordinators are the central contact person for the
division or office for all matters related to QA and serve as champions of QA activities
within their respective Divisions. The RQAM and the QA Coordinators will work together
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to ensure that an effective quality system will be consistent in all Region 4 Divisions. The
QA Coordinators will:
•	Serve as the official Division/Office contact for quality assurance matters pertinent
to the data collection activities of thatDivision/Office.
•	Attend the initial QAPP, QMP, DQO training classes, along with the workshop
classes for the Region 4 QMP.
•	Attend quarterly QA Coordinators' meetings convened by the RQAM to keep
abreast of QA issues affecting the Region and Agency. Communicate QA issues to
Division/Office personnel.
•	Attend Regional QA training provided by the RQAM in the Region as appropriate.
•	Respond to quality control issues and problems, and respond to requests for
guidance or technical direction.
•	Work with the Division's staff to develop and maintain an effective QA program.
•	Responsible for the preparation and review of their Divisional/Program QMP.
•	Advise the RQAM on changes needed to the Regional QMP.
•	Coordinate Division/Program input for the Regional QA Annual Report and Work Plan
(QAARWP) submitted by the RQAM to OEIEQMD Director. The report will be in the
framework of QA Metrics measuring all QA inputs, activities, interim outcomes, and
outcomes.
•	Maintain an inventory of QAPPs for their Division/Office for tracking purposes, if the
Designated Approval Authority has approved QAPPs in their division. The QA
Coordinator will not be responsible for reviewing, or approving QAPPs and QMPs. If
questions for review, inventory, oversight, etc. are involved concerning QAPPs or
QMPs, the RQAM or designee should be contacted for assistance.
•	Work with the RQAM or designee to maintain an accurate and up-to-date list of DAOs
for their Division/Office.
3.2.5 Regional Project Managers
Project Managers, however named, are responsible for specific internal regional projects.
Therefore, the Project Manager ensures that project objectives are met and that the data
collected to support project decisions meet national and regional QA requirements. The
Project Manager:
•	Prepares or directs the preparation of a QAPP (or equivalent planning document) for
each project and submit the QAPP to the RQAM or a Divisional DAO for review and
approval.
•	Prepares or approves Data Quality Objectives, technical and quality assurance
specifications, and acceptance criteria for environmental data needed to support
project decisions.
•	Participates in conducting QA system/performance audits of projects as requested by
the RQAM.
•	Takes corrective action that may be required by audit findings.
•	Reports data quality problems to the regional QA Coordinator located within the
appropriate Organization/Program and the RQAM.
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•	Attends appropriate regional QA training provided in the region.
•	Reviews QAPPs that are submitted to the Region as part of EPA's documentation
requirements. The QAPP is to be reviewed using the appropriate QAPP Review
Checklist. See Appendix C, pages 66 - 79, for QAPP Review Checklist.
3.2.6	Regional Project Officers/Contracting Officer Representatives
Project Officers (POs) are accountable for specific extramural assistance agreements while
Contracting Office Representatives (CORs) are accountable for contracts. Therefore, while
the POs/CORs are normally not directly involved in project activities, the POs/CORs
ensure that all Agency QA requirements are met by the assistance agreement recipient or
contractor. The POs/CORs:
•	Require preparation of a QMP, QAPP, and/or equivalent document, as appropriate,
for each assistance agreement or contract.
•	Overview data quality generated from external projects funded through financial
assistance agreements and/or contracts.
•	Complete the required QA Review Form (QARF) in accordance with Chapter 46 of
the EPA Acquisition Guidelines. (CORs only)
•	Participate in conducting QA system and performance audits of projects as requested
by the RQAM.
•	Coordinate review of external QMP and/or QAPPs and submit to RQAM for review
and approval.
•	Take corrective action that may be required by audit findings.
•	Report data quality problems to RQAM and the appropriate QA Coordinator.
•	Attend appropriate regional QA training.
•	Review QAPPs that are submitted to the Region as part of grant/as si stance
agreement and contract requirements.
3.2.7	Regional Program Technical Staff
Technical staff support the RQAM by providing technical assistance in their area of
expertise if requested by the RQAM. This enhances the QA capability in Region 4. The
specific duties assigned to the technical specialists are to:
•	Assist the RQAM with technical aspects of QA as related to their expertise
in air, water, toxic substances, hazardous waste, engineering, chemistry,
biology, microbiology, field operations and data operations.
•	As needed, review technical aspects of QAPPs that are submitted to the
Region as part of grant/assistance agreement and contract requirements.
•	Identify QA needs, resolve problems, and answer requests for guidance or
assistance in area of expertise.
•	Conduct and/or participate in on-site field and laboratory system and
technical audits.
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• Participate in technical assistance and training of State/Tribal/local, and
private laboratory personnel in EPA methods, instrumental and QA
requirements.
3.2.8 Designated Approving Officials
A Designated Approving Official (DAO) is a regional manager or staff person who has
been delegated the authority by the RQAM to approve QAPPs The DAO is expected to
review the QAPP to ensure that it is compliant with the requirements specified in EPA's
QA/R-5 document, and follow prescribed procedures for reviewing, documenting, and
approving QAPPs and must attend the DAO training course coordinated by the RQAM.
Each division/office must include the protocols for DAOs in its QMP and such protocols
must conform to those outlined in this QMP. Managers and supervisors are responsible
for identifying prospective DAOs within their organizations.
To receive and maintain certification as a DAO, the individual must fully meet the
following requirements:
Prospective DAO Education and Technical Knowledge
1.	Should have at least a Bachelor's Degree in any of the physical or biological
sciences, environmental engineering, or demonstrate an in-depth understanding
of these disciplines based on hands-on job experience obtained internal or
external to the agency.
2.	Possess a clear understanding of the analytical methodologies or biological
analyses/determinations usually employed for environmental investigations and
must be familiar with sampling techniques and QA requirements. If biological
parameters require collection and analysis/determination, the prospective DAO
must either consult with the RQAM, or designated SESD QATSB/QAS staff
on these issues or must be familiar with the requirements for collecting this
information to approve the QAPP.
3.	A firm knowledge of EPA program and regulatory requirements as appropriate
to the program, is necessary.
4.	Possess the necessary expertise in project management to review the QAPP.
5.	The prospective DAO must have no direct conflict of interest. A project
manager who writes a QAPP for a project under his/her direction cannot
approve that same QAPP.
6.	The QAPP review process must be documented using a checklist developed by
SESD QATSB/QAS (See QAPP checklist in Appendix C), or similar program-
specific checklist, and include specific comments addressing document
deficiencies as needed.
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Training Requirements and Certification Process
1.	Satisfactorily complete an initial 4-hour training course provided by SESD
QAS staff on QAPP requirements and review, Data Quality Objectives (DQO),
and the QAPP Checklist.
2.	After completion of the initial training, the prospective DAO must complete
and submit the DAO Technical Competency Form to the RQAM documenting
his/her educational and technical knowledge.
3.	The RQAM reviews the form for completeness and competency.
4.	Upon approval, the RQAM forwards the Technical Competency form to the
designated SESD QATSB/QAS staff for filing and development of the DAO
certificate. The DAO certificate will then be emailed to the DAO with a copy
to the respective divisional QA Coordinator. The SESD QATSB/QAS staff
will track the status of the DAOs.
5.	To maintain continuing certification, the DAO must attend annual DAO
refresher training available on-line via the EPA e-Learning or by webinar, as
scheduled.
a.	Annual refresher training must be completed by the end of the
following calendar year.
b.	If the annual refresher training is not completed by December 31 st, the
DAO certificate will expire and the DAO will not be allowed to
approve QAPPs. To be re-instated as a DAO, the initial training must
be re-taken and a new Technical Competency form submitted to the
RQAM for approval.
6.	DAO certification is not allowed to transfer into other programs. If the DAO
moves to another program, he/she must be retrained and re-certified in that new
area/program. If the DAO is current in his/her refresher training, he/she will
not be required to re-take the initial DAO training, but must demonstrate the
necessary technical competency in the new program area.
3.2.9 Field Quality Coordinators
The FQCs ensure the Region implements and maintains a quality management system in
conformity with the QAFAP requirements. Duties may vary by division but include the
following:
•	Oversees all aspects of QAFAP implementation within their division/program.
•	Works with subject matter experts to ensure development of applicable program-
specific technical SOPs.
•	Assists the RQAM with the coordination of internal/external audits and ensures
corrective actions are initiated and completed.
Communicates regularly with management concerning the status of the quality
management system and make recommendations for improvements.
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•	Reports on the performance of the Management System to divisional QA
Coordinator, Regional Senior Managers, and RQAM as needed.
•	Provides input for the Annual QA Report and Work Plan.
4.0 REGIONAL QUALITY SYSTEM REQUIREMENTS - EXTERNAL
ORGANIZATIONS
4.1 State. Local and Tribal Grants
A substantial amount of environmental data required by EPA statutes and regulations are
generated by state, local, and tribal organizations receiving one-time or continuing
environmental grants. To qualify for financial assistance, state, local, and tribal organizations
must meet the QA requirements in 2 CFR 1500.11.
4.1.1	To satisfy the QA requirements in 2 CFR 1500.11, the assistance agreement
recipient must submit a QMP for review and approval (at a minimum of every 5
years) by the RQAM and the appropriate assistance agreement Project Officer (PO).
If there are significant organizational changes, delegation authority modifications,
etc., then a QMP will need to be updated to reflect those changes and submitted for
approval prior to the five-year cycle. For a grantee's QMP to be approved, the
grantee's quality system must meet the specifications of EPA Requirements for
QMPs (EPA QA/R-2), March 2001 (or most recent edition). If grantees make sub-
awards (either sub-grants or procurement) under an assistance agreement, they must
ensure that the sub-awards meet the quality assurance requirements in EPA QA/R-2.
4.1.2	Clarifying language provided by EPA's Office of Grants and Debarment also
requires the grant recipient to provide a QAPP in addition to the QMP. In addition, for
continuing grants such as performance partnership grants (PPGs), where a single grant
may cover several projects or studies and programs, each of these projects or studies
will require a QAPP to meet the grant conditions. QAPPs will be developed using the
graded approach depending on the complexity and intended use of the data being
collected. Where grants are awarded to fund numerous, similar projects by the same
organization, the preparation of a program-level QAPP in lieu of numerous individual
project QAPPs may be appropriate. The management within the program will make
the determination when a program-level QAPP is appropriate.
4.1.3	While state, tribal and local agencies are responsible for managing theQA
programs under their grants, the Region retains overview responsibilities. The major
overview functions are work plan reviews, program evaluations, and quality assurance
assessments. QA input for these overview functions include QMP review/approval,
QAPP implementation, and may include on-site QA audits of environmental programs,
field activities, and laboratory operations. State program overview is the primary
responsibility of the individual regional program division/office with extensive
assistance from the RQAM and SESD personnel.
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4.2 Academic. Hospital and Non-Profit Grants and Cooperative Agreements
2 CFR 1500.11 contain QA requirements for grants and cooperative agreements with
institutions of higher education, hospitals and other non-profit organizations. These grants are
usually one-time assistance agreements as opposed to the continuing grants awarded to state,
local and tribal organizations. The academic/non-profit QA requirement is satisfied by the
grantee's submission of a QMP and QAPP, with subsequent approval of the QMP and QAPP.
The QMP and QAPP may be combined into a single document if the RQAM and Project
Officer agree that the nature and extent of the environmental data collection effort warrants
such action. QMPs and QAPPs will be approved by the RQAM and the appropriate Project
Officer(s). It is recommended that QAPPs be approved prior to award. However, if the
QAPP is not approved prior to award, then the assistance agreement will be conditioned to
require an approved QAPP before data collection begins. If grantees make sub-awards
(either sub-grants or procurement) under an assistance agreement, they must ensure that the
sub-awards meet the quality assurance requirements specified in EPA's QA/R-2 document.
4.3	QA Operations for Interagency Agreements
For interagency agreements, before funding for environmental measurements or data collection
activities is approved, EPA Region 4 and the other involved organizations must have agreed
upon the QA requirements for the project. The organization receiving the funds is responsible
for preparing the QMP or equivalent document. If the external organization's documented
quality system meets the requirements found in the EPA Requirements for QMPs,
EPA QA/R-2, March 2001 or the Intergovernmental Data Quality Task Force: Uniform
Federal Policy for Implementing Environmental Quality Systems, EPA-505-F~,03-001,
March 2005, its QMP, or equivalent document shall be acceptable. If comparable QA
procedures do not exist, the QA procedures agreeable to both parties must be negotiated for the
Interagency Agreements. Before any environmental data operations can be performed, the
external organization must have an approved QMP and QAPP (or equivalent documents) or
successfully negotiated and acceptable to both parties. These QA requirements are in
accordance with the specifications provided in EPA Requirements for QAPPs,
EPA QA/R-5, March 2001, or the Intergovernmental Data Quality Task Force: Uniform
Federal Policy for QAPPs, EPA-505-B-04-900A, March 2005, as appropriate.
The QAPPs will be prepared post-award and will be reviewed and approved by either the
RQAM or a Designated Approving Official. Upon completion of the monitoring activities, the
Project Officer shall assess the data quality of the planned activity. If data quality issues arise
with the collected data, these issues shall be communicated to the RQAM or designee for
resolution.
4.4	Quality Management Plans for External Organizations
The following requirements must be met by those organizations submitting QMPs to
Region 4 for grants, contracts, and cooperative agreements:
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4.4.1	The QMP must satisfactorily address the main topic areas addressed in
"EPA Requirements for Quality Management Plans," EPA QA/R-2,
EPA240/B-01/002, March 2001, or most recent version.
4.4.2	QMPs must include a description of review and approval process for project
or study-specific QAPPs covered by the assistance agreement. QMPs will be
reviewed by the RQAM, SESD QATSB/QAS personnel and the appropriate
assistance agreement project officer. The appropriate assistance agreement project
officer will coordinate the review of the QMP for their specific extramural agreement.
QMPs shall be approved for a period of no longer than five years.
4.4.3	The Facilities, Grants and Acquisitions Management Branch (FGAMB)
within the Office of Policy and Management will review extramural agreements prior
to award to ensure that all Agency quality requirements have been documented. The
RQAM will provide GAMS staff and regional project officers with a listing of
approved QMPs and the expiration dates for State and Tribal continuing assistance
agreements.
4.4.4	Only the RQAM may approve an external organization's QMPs.
4.5 Quality Assurance Project Plans for External Organizations
The following requirements must be met by those organizations submitting QAPPs to
Region 4 for grants, cooperative and interagency agreements:
4.5.1	The QAPP must satisfactorily address the topics specified in the document
entitled "EPA Requirements for Quality Assurance Project Plans", EPA QA/R-5, Final,
February 2006, or most recent version.
4.5.2	In reviewing QAPPs, the RQAM or Designated Approving Official will use
the graded approach, where appropriate, recognizing that each data collection project
or study is different. Simpler projects may require QAPPs which are not as detailed as
those covering more complex projects.
4.5.3	The document entitled "EPA Guidance for Quality Assurance Project
Plans" EPA QA/G-5, Final, December 2002, or most recent version, provides
detailed information for preparing an EPA required QAPP document.
5.0 REGIONAL QUALITY SYSTEM - INTERNAL ORGANIZATIONS
This section describes the quality system requirements for environmental data generated within
Region 4's programs/organizations (internal data). An overview of the quality system policies,
procedures, roles, and responsibilities are described in this QMP. According to CIO 2105.0, "All
Agency organizational units governed by CIO 2105.0, shall document their quality system in a QMP.
The QMP is a policy statement describing how an EPA organization shall comply with the
requirements of EPA CIO 2105.0. The QMP provides the blueprint for how an individual EPA
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Program Office, Region, and National Laboratory or Center will plan, implement and assess its
quality system for the environmental work to be performed as part of its mission."
5.1 Divisional Quality Management Plans (OMPs)
To ensure that Region 4 divisions and programs are adhering to the requirements and
specifications outlined in the CIO Policy and the Regional Quality System/QMP, each
division will develop and implement a QMP tailored to its management structure, QA
policies, procedures and practices. Each QMP will provide:
5.1.1	The clearly delineated management structure of each division, and clearly
defined roles (including DAOs and QACs) and responsibilities of division/program
management, personnel and contractors.
5.1.2	An overview of data collection operations that are fully compliant with
EPA's data quality objective process as outlined in EPA's QA/G-4 document.
5.1.3	The specific measurements undertaken by the division for determining the
effectiveness of the divisional quality system in meeting regional goals and objectives as
outlined by the RQAM or the RA. If deficiencies in the quality system are identified, the
division must develop and implement a corrective action plan to mitigate deficiencies.
5.1.4	A detailed plan for overseeing, on an annual basis, the technical,
programmatic and QA functions of State, Local and Tribes receiving EPA grant or
assistance agreements.
5.1.5	The internal management, technical and QA assessments performed by
divisional/program staff to identify any areas of vulnerability or non-compliance with
divisional or regional requirements.
5.1.6	The system of documenting and communicating assessment findings to
divisional/programmatic management. Assessment findings shall be reported to
divisional management, senior management and the RQAM. Corrective measures in the
form of recommendations and/or corrective actions will be implemented to mitigate
vulnerabilities or non-compliance issues.
5.1.7	Delineate the process for overseeing State, Local and Tribes that have been
delegated self- approval authority for QAPPs prepared within divisions/programs. The
division QMP shall specify the number, type and frequency of QA oversight activities or
assessments. The RQAM will ensure that the divisions and/or programs comply with
Region 4 requirements for maintaining delegated self-approval authority.
Note: Currently, no State, Local or Tribal programs have received delegation for self-
approval authority. However, before Region 4 would delegate this responsibility to the
State, Local and Tribes, the RQAM would seek guidance from EPA OEI before
implementation.
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At the project level, the Region relies on project level quality documentation to describe
project quality assurance and quality control procedures: the QAPP. It is generally
recognized within the Region that other technical project level work plans, however
named, must be equivalent to and compliant with the QAPP requirements specified in
EPA's QA/R-5 document. For example, in the Superfund program, a Sampling and
Analysis Plan may be used to document project level technical activities.
5.1.8 Divisional QA Coordinators are responsible for the preparation and review of
its respective divisional QMPs. Draft QMPs must be submitted to SESD QATSB/QAS
for review. Following review by the designated SESD QATSB/QAS personnel, the
RQAM will review the draft divisional QMP. The RQAM approves all divisional QMPs.
5.2	Internal Data Operations
EPA Project Managers or their designees are responsible for preparing QAPPs when the
projects involve the collection of environmental data or the use of environmental technology.
The RQAM is available to assist in the development of QAPPs by discussing the Agency's
requirements for QAPPs, but will not directly participate in writing the plan. The RQAM or
his/her designee shall review and approve all QAPPs for internal data collection prior to the
initiation of field operations.
5.3	QA Operations for Contracts
Since the mission of the regional programs is to protect human health and the environment
rather than to produce a manufactured product, it is not anticipated that most regional
divisions will procure manufactured items which impact the quality of data. Therefore, the
inspection of routine procured items is not an element of the quality system for organizations
other than SESD. Because one of SESD's primary missions is to produce data which support
other divisional programs, SESD's standard operating procedures contain instructions on
evaluating the suitability of manufactured items which are critical to data generation process
(e.g. sampling equipment, laboratory instrumentation, reagents and supplies). The first line
supervisors in SESD are responsible for including quality specifications in purchase requests
and for inspecting or delegating the inspection of equipment and consumables to assure the
items meet the quality specifications.
Many regional divisions use contractors for the collection of environmental data or utilizing
environmental technology. During the contract pre-award phase, the originating program
division shall notify the RQAM of all contracts involving the collection, generation, use, or
reporting of environmental data, and/or the design, construction, and operation of
environmental technologies. Normally the types of contracts which will require the
generation of quality assurance documentation are those in which services are procured.
Examples of these types of service contracts include contractor analytical operations,
sampling/field measurements, data assessment, site investigations, etc.
The QA requirements in the Federal Acquisition Regulations (FAR) 46.202-4 and
FAR 52.246-11 (Higher-Level Contract Quality Requirement, Dec. 2014) apply to regional
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contracts involving the collection and use of environmental data. The appropriate Contracting
Officer Representative (COR) is responsible for ensuring that all solicitations for work
involving environmentally-related measurements meet the Higher-Level Quality
Requirements specified in FAR 52.246-11. In addition, the COR shall ensure that a QA
Review Form has been completed in accordance with the EPA Acquisition Guidelines. The
COR is also responsible for including the RQAM as a technical evaluation panel member on
those contracts that involve the collection, generation, use, or reporting of environmental data,
and/or the design, construction, and operation of environmental technologies in the following
situations:
•	The potential value of the procurement exceeds $650,000; or
•	The estimate of the percentage of costs or level-of-effort allocated to activities
requiring quality requirements exceeds 15%; or
•	Procedures defined in the Agency-approved QMP of the organization sponsoring the
work apply.
The Acquisition Management Section within the Office of Policy and Management ensures
that QA Review Forms, with appropriate signatures, are included in every solicitation
package. The QA Review Form specifies if environmentally-related measurements are
required under the contract's scope of work, and if so, which type of quality assurance
documentation is required under the contract. The default submissions for contracts requiring
the collection, generation, use, or reporting of environmental data, and/orthe design, construction, and
operation of environmental technologies are a QMP prior to award and a QAPP for each
applicable project post-award. The QMP and QAPP may be combined into a single quality
assurance document if agreed to before contract award by the contract COR and the RQAM.
The Region 4 Acquisition Management Section will ensure that QMPs are reviewed and
approved by the RQAM for those contracts requiring the collection, generation, use, or
reporting of environmental data, and/or the design, construction, and operation of
environmental technologies.
6.0 REGIONAL QUALITY SYSTEM COMPONENTS
Planning, implementation and assessment processes are necessary to effectively conduct
environmental data collection operations and the use of environmental technology. The
elements of the regional quality system include activities in the planning, implementation and
assessment phases. The planning process is documented in the Divisional QMPs and QAPPs.
The implementation phase is performed and overseen by the data user and/or project
manager/leader, and the assessment phase is conducted as specified in the applicable project
planning document. The components and procedures described below are used for the
collection of environmental data by Region 4 personnel.
6.1 Data Quality Objectives
The data quality objectives (DQOs) process is EPA's systematic planning process which
uses a step-wise system of developing the technical, programmatic and quality assurance
requirements specific to a project or study. Detailed guidance for developing project or
study-specific DQOs is provided in "Guidance on Systematic Planning Using the Data
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Quality Objectives Process, EPA QA/G-4, EPA/240/B-06/001 (February 2006). The
Agency's DQO process is the preferred method of developing objectives for those projects
requiring the collection of environmental data or the use of environmental technology.
However, any systematic planning process may be used if it results in the development of a
QAPP that meets EPA requirements.
Having identified the need for an environmental data collection effort, the decision maker
(i.e., Branch Chief, Section Chief, Project Manager, etc.) is responsible for initiating the
DQO process. During the early planning phase of the investigation, the data user must
clearly establish the intended use of the data, time and resource constraints, and the quality
of data needed. The project manager is responsible for development of DQOs that will
facilitate the generation of data that is of sufficient quality and quantity to support
environmental decisions. The DQO process requires interaction between the project
manager, field and laboratory technical staff, QA staff, and primary and existing data users
as appropriate. The DQOs developed will be used for the detailed design of the investigation
and preparation of the QAPP.
The RQAM will be the focal point for providing guidance and review of DQO development.
The RQAM will consult with other Regional technical staff on DQO issues outside the
technical expertise available within the SESD QATSB/QAS. A rigorous treatment of the
statistical hypotheses and decision error types as outlined in Chapter 6 of the EPA QA/G-4
document may require consultation with a statistician.
6.2 Quality Assurance Project Plan Contents
Region 4 relies on QAPPs, coupled with detailed SOPs, to define project-specific quality
assurance/quality control (QA/QC) requirements. In preparing a QAPP, the project manager
must identify the project objectives, project management team, sampling design, critical
measurements to be performed, and discuss the QA/QC activities to be conducted during the
sampling, analytical, and data validation phases of the project. The document entitled "EPA
Requirements for Quality Assurance Project Plans," (EPA QA/R-5), EPA/240/B-01/003
(March 2001) document provides basic instructions for preparing QAPPs. The content of
Regional QAPPs shall adhere to the requirements of EPA QA/R-5, most recent version. The
document entitled "EPA Guidance for Quality Assurance Project Plans" (EPA QA/G-5),
EPA/240/R-02/009, (December 2002) provides detailed information for developing a QAPP.
Within the region, different organizations may refer to the project-level planning document
using terms such as "sampling and analysis plan" or "study plan." However named, the
project- level planning document will contain the necessary elements specified in EPA
QA/R- 5, while at the same time considering the application of the graded approach to the
planning document.
All EPA regional projects requiring collection of environmental data or the use of
environmental technology must have an approved QAPP. An exception to this requirement
is for those projects where immediate danger to human health or the environment is present
or suspected. Projects involving environmental technology shall follow the EPA "Guidance
on Quality Assurance for Environmental Technology, Design, Construction and Operation"
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(EPA QA/G-11), EPA/240/B- 05/001 (January 2005) document. The RQAM, or a
designated approving official, shall review all QAPPs, provide input, recommend changes,
and approve final plans. The RQAM may solicit assistance from regional technical staff
when specialized expertise is needed to review certain QAPPs. Project QA activities are
tracked by the appropriate Project Manager.
6.3 Standard Operating Procedures (SOP)
Standard Operating Procedures are documented protocols for performing certain routine
repetitive tasks. These tasks frequently involve such operations as sample collection, chain of
custody, analysis methods, instrument or method calibrations, preventive and corrective
maintenance, quality control, and data reduction.
SOPs for field activities will be conducted in accordance with the QAFAP requirements.
Region 4 has developed overarching SOPs that serve as the basis for implementation of the
QAFAP. Region 4 divisions and/or programs may establish alternate standard operating
procedures addressing the corresponding requirements and consistent with regional practice
with the concurrence of the RQAM. When such alternate procedures have been established,
these procedures form the basis for quality assurance evaluation of field activities in that
division and/or program. Region 4 QAFAP procedures can be found on the EPA Region 4
Field Operations Intranet Site.
6.3.1	Preparation of SOPs
SOPs are prepared by the regional organization which has determined that a certain
task, procedure, or job function must be performed in a uniform, consistent manner by
multiple personnel. The purpose of an SOP is to minimize or reduce random error
occurrences due to differences in performance of a task. It is advisable that SOPs be
prepared by personnel who are most knowledgeable in a specific task or procedure.
The SOPs are reviewed by appropriate staff in the user organization, and at times by
technical specialists in other organizations. The SOPs are prepared in document
control format by the user and are to be maintained on permanent file by the
originating organization. In addition to the QAFAP requirements for document
control, the EPA document entitled "Guidance for the Preparation of Standard
Operating Procedures" (EPA QA/G-6), EPA/240/B-01/004 (March 2001), could be
consulted for an example of the document control format. SOPs are dynamic
documents that are revised as needed. SOP revisions may be the result of changes in
regulations, procedures, instruments and equipment, or by inadequacies noted during
implementation and/or audits.
6.3.2	Standard Operating Procedure Criteria
The following are considerations involved in the development and utilization of
Standard Operating Procedures. SOPs should be:
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6.3.2.1	Adequate to establish traceability of standards, instrumentation,
samples, and environmental data.
6.3.2.2	Simple, so a user with basic education, experience and/or
training can properly use them.
6.3.2.3	Complete enough so the user/reader follows the directions in a
systematic manner through the sampling, analysis, and data-handling process.
6.3.2.4	Consistent with sound scientific/engineering principles.
6.3.2.5	Consistent with current EPA regulations and guidelines.
6.3.2.6	Consistent with the instrument manufacturers' specific instruction
manuals.
6.3.2.7	At a minimum, a review of SOPs will occur every four years.
However, the SESD laboratory and Field Services Branch will perform SOP
reviews in accordance to ISO 17025 accreditation requirements.
6.3.3 Activities Requiring Standard Operating Procedures
The following protocols related to the collection of environmental data will be
addressed in SOPs:
6.3.3.1	General sampling procedures.
6.3.3.2	Analytical methodology.
6.3.3.3	Sample collection devices, storage containers, and sample additives
such as	preservatives.
6.3.3.4	Instrumentation selection and use.
6.3.3.5	Instrumentation calibration and standardization.
6.3.3.6	Instrument preventative and remedial maintenance.
6.3.3.7	Duplicate, spiked, blank samples and analysis.
6.3.3.8	Field and laboratory quality control procedures.
6.3.3.9	Sample documentation, sample custody, transportation, and handling
procedures.
6.3.3.10	Field and laboratory safety.
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6.3.3.11
Data management and assessment procedures.
6.3.3.12 Document control.
6.3.3.13	Field personnel training and training records.
6.3.3.14	Field documentation
6.3.3.15 Records management
6.3.3.17	Planning field activities
6.3.3.18	Field report preparation.
6.4 Data Processing. Verification, and Validation
Data processing includes collection, reduction, transfer, verification, and storage. Precautions
shall be taken each time the data are reduced, recorded, calculated, and transcribed to prevent
the introduction of errors and the loss of information. Data processing requirements are as
follows:
6.4.1	Collection: Each field and laboratory SOP, as appropriate, shall address the
steps which must be used to avoid errors in the sample collection or sub- sampling
process.
6.4.2	Verification: Data verification is the process of evaluating the
completeness, correctness, and conformance/compliance of a specific data set against
the method, procedural, or contractual requirements. Data verification procedures will
be specified in the applicable laboratory SOP, QA Manual, QAPP, or data review
SOP.
6.4.3	Validation: Data validation is defined as an analyte and sample specific
process that extends the evaluation of data beyond method, procedural, or contractual
compliance (i.e., data verification) to determine the analytical quality of a specific data
set. Criteria for data validation shall be specified in the applicable QAPP.
6.4.4	Storage: Each SOP, as appropriate, shall indicate how specific types of data
will be stored.
6.4.5	Transfers: Each SOP, as appropriate, shall describe procedures which shall
be used to ensure that data transfer is error-free, and that no information is lost in the
transfer. Data transfer steps shall be kept to a minimum.
6.4.6	Reduction: Each SOP, as appropriate, shall contain procedures for ensuring
the correctness of data reduction processes. Data reduction includes all processes which
change either the form of expression or quantity of data items. It is distinct from data
transfer in that it entails a reduction in size (or dimensionality) of the data set. It's also
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the process of converting raw data from analytical instruments/measurements to final
results. Each SOP, as appropriate, shall describe procedures for verifying the accuracy
of the data reduction process.
6.5	Data Quality Assessment
Each QAPP shall include procedures for assessing the quality of all environmental data
generated for accuracy, precision, completeness, comparability and representativeness.
Detailed guidance for assessment may be found in EPA's "Data Quality Assessment: A
Reviewer's Guide, (EPA QA/G-9R), February 2006 andData Quality Assessment: Statistical
Tools for Practitioners, (EPA QA/9S), February 2006 documents.
6.6	Corrective Action
Each QAPP shall include provisions for QA reporting or feedback to the responsible
management to ensure that early and effective corrective action can be taken when data
quality falls outside established data quality objectives, data acceptance criteria or quality
assurance requirements. Each QAPP shall also include provisions to keep management
informed when corrective actions are necessary. Corrective action shall relate to the overall
QA management scheme: who is responsible for taking corrective actions when required,
who follows-up to verify that corrective actions have been taken, and whether actions have
produced the desired results. Corrective actions shall be documented and a formal system of
communicating these actions to key project personnel, senior level management, and EPA
personnel should be established by the data collection entity.
6.7	Information Management
EPA's Office of Environmental Information (OEI), Office of Information Technology
Operations (OITO) is responsible for managing the hardware, software and communications
components that form the foundation of the Agency's information technology. OEI/OITO has
established the hardware and software standards with which the region must conform.
Region 4 managers and staff will observe all hardware and software standards as detailed in
the OITO Directives System at http://basin.rtpnc.epa.gov/ntsd/directives.nsf. This directives
system is applicable to the personal computer platform, local area network and server
platforms, open systems platforms, Agency electronic mail service and Supercomputer
platform.
Specifically, Region 4's Information Systems Management Branch (ISMB) is responsible for
assessing significant changes in the Agency's hardware and software policy to determine any
impact on the Region. In the event changes are required, ISMB will work with regional
management to plan and implement appropriate modifications. Region 4 will procure
Agency-approved hardware and software that conforms with the Agency's enterprise
information architecture and structure. This is projected in the development of an annual
spend plan and strategic plan.
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Hardware
It is very important to select good quality stable hardware to avoid program failure, since
poor quality hardware can be costly to EPA. Region 4 currently purchases only Dell
hardware for servers and workstations since it is recommended by the Agency.
Hardware evaluation comes in two distinct categories:
•	to replace an existing server or workstation
•	to acquire hardware for a new system
This process is reviewed on an annual cycle. Region 4 replaces critical systems hardware
every 4 years. Determining factors for what equipment is replaced is based on the operating
system, Agency software standards and cost of warranty versus replacement. Some
non-critical systems can run on an older hardware platform beyond the warranty period
provided by the system manufacturer.
Purchasing new hardware is determined by key factors that include: number of users,
software, disk space, processing speed and applications. After these factors have been
determined, the Region 4 process for installing new servers is as follows:
1.	Install proper operating systems
2.	Follow EPA guidelines for security settings
3.	Install Symantec Antivirus
4.	Install all CSIRC approved critical patches
5.	Request IP address for server
6.	Configure and install server according to application using EPA guidelines
7.	Add server to appropriate network directory
8.	Begin testing phase
9.	Evaluate performance of network, application response and user connectivity
10.	Correct any issues/problems identified during performance evaluation phase
11.	Bring server online for production
12.	Document and save server information after completion
Software
Region 4 complies with the Agency's System Life Cycle Management (SLCM) policy as a
guide for all application/software development. The Region 4 Application Development
Manager (ADM) reviews initial requirements to determine if an existing application will
meet program needs. If a new application is needed, the ADM continues requirements
discussions. Requirements are agreed to by both application program sponsor and application
manager. Depending on the requirements, available EPA-approved software/platforms and
programming expertise, decisions are made on what technology platform will be used to
develop the application. Development then begins and is continued with ongoing
discussions with the program.
Region 4 employs the Agile project management methodology to provide more rapid
development of applications and demonstrate early success. The ADM is an ICAgile
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(International Consortium for Agile) certified practitioner. Application testing plans are
created and carried out in short 'sprints' and continuous activities with controlled audiences
specific to the intended user base. Areas of consideration for identifying testing groups
include (but are not limited to) hardware differences and user's IT experience. Test results are
reviewed, and then changes/modifications are made as needed. Additional testing is
completed if needed.
The ADM documents all requirements and creates maintenance, security and record plans.
The application is then implemented. Follow-up meetings are scheduled and conducted as
necessary. Application duplication is avoided by comparing all development and purchase
requests to existing systems.
If a program has a need to purchase 'non-standard' application software that is not on
Agency contract, the software will be evaluated prior to purchase. Software evaluation will
be performed against written performance/ capability standards developed by the
Application Administrator and/or System Administrator. Region 4 will evaluate system and
software documentation to ensure that vendors comply with Agency standards, and to
determine its performance capabilities and documentation requirements.
IT Support Services
After deployment of new hardware or software, Region 4 IT Technical Support Services
receive 'service' calls for troubleshooting and/or repair of equipment or software via the
Remedy Helpdesk ticketing system. These calls are captured and documented. Remedy can
run online reports of categorized service calls that are evaluated to determine what
corrections are needed.
Roles and Responsibilities
Region 4 System Administrators manage the entire network including hardware, software and
user profiles. Responsibilities include ensuring server, switches, and computer images are
properly configured according to EPA specifications and guidelines.
Region 4 Database and Application Administrators manage and maintain the Oracle and
SQL server databases and applications on the server. Responsibilities include ensuring
that databases and applications are accessible to users always and that maximum uptime
is maintained.
Region 4 IT Technical Support Services manage desktop hardware and software.
Responsibilities include repair, upgrading, and user training of equipment and Agency
standard software.
R4 Information Security Officer is responsible for ensuring the network and all desktops
follow the guidelines for security settings and policies of operation.
Region 4 uses 'Patchlink' reports to ensure that servers are following EPA information
security requirements.
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IT managers and supervisors are responsible for approving all activities of purchasing
software and hardware. They are also responsible for day-to-day activities to ensure the
network is functioning properly.
6.8 Data Quality Act/Information Quality Guidelines
The Data Quality Act/Information Quality Act [Section 515(a) of the Treasury and General
Government Appropriations Act for FY 2001 (P.L. 106-554)] requires Federal agencies to
develop guidelines for ensuring that quality information is disseminated to the public. The
U.S. Office of Management and Budget (OMB) has oversight responsibility for
implementation of the Act, and the Office of Environmental Information (OEI),
Environmental Quality Management Division (OEI EQMD) has responsibility for
implementation in the Agency.
Pursuant to these requirements, EPA issued the Information Quality Guidelines (IQG)
officially titled "Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility,
and Integrity of Information Disseminated by the Environmental Protection Agency") in
October 2002. The IQG contain policy and procedural guidance for ensuring "disseminated
information" is accurate, reliable and unbiased, useful to the intended user, and secure from
compromise.
The IQGs provide the opportunity for industry, private citizens, environmental organizations,
or members of Congress to challenge the quality of information disseminated by any means
by the Agency and to request corrections for EPA consideration. For purposes of IQG,
Region 4 defines "information" as any communication on positions or policy, including facts
or data adopted or endorsed by the Region. Information disseminated by the Region falls into
the following six types of information:
a.	Tools (data query, models, estimator tools, mapping/GIS-related)
b.	Reports, journal articles, studies, trends analyses
c.	Databases (searchable databases)
d.	Guidance documents (training materials, user guides)
e.	Outreach products (action plans, brochures, conference proceedings)
f.	Information disseminated in support of regional decisions or policies (studies,
assessments, and other supporting information)
Region 4 will, to the extent practicable, ensure that all information products subject to the
Guidelines adhere to the quality principles of objectivity, utility, and accuracy. In addition,
the Region will also ensure transparency and reproducibility of data as quality criteria for
"Influential" information. For purposes of IQG, "disseminates" means when the Region
initiates or sponsors the distribution of information to the public.
In 2006, EPA OEI developed Pre-Dissemination Review (PDR) Guidelines to serve as a
template for Offices and Regions in reviewing information products subject to the IQG
before they are "disseminated." Region 4 will focus on ensuring that the Region's quality
criteria discussed above build these principles into each step of the development of
information, including its creation, collection, maintenance, and dissemination. All regional
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Pre-Dissemination Review protocol and review procedures will incorporate these goals and
policy as review criteria for disseminated information.
Region 4 Pre-dissemination Review procedures include programmatic and legal reviews, and
QAPP and QMP reviews, as applicable, prior to dissemination. Peer Review will also be
used, when appropriate, under OMB guidance. Branch Chiefs or designee will be responsible
for developing and implementing PDR as appropriate in their areas of responsibility and will
serve as the information product approver before such products are disseminated. The
RQAM will be responsible for auditing division's implementation of IQG and PDR to be
sure that IQG data quality criteria are incorporated into regional policy and decision making
and that PDR procedures follow the PDR guidelines.
The RQAM will be the point of contact for OEI to direct them to the appropriate program
that will be responsible for coordinating the review of any Requests for Correction or
Requests for Reconsideration received on any Region 4 information product.
The RQAM will be responsible for bringing appropriate training to the Region for managers
involved in pre-dissemination review and for staff who develop information products. The
RQAM, in coordination with OEI, will provide regional guidance on IQG and PDR, as
needed, and will get program input and management approval on needed guidance.
7.0 QUALITY SYSTEM ASSESSMENT
7.1 Assessment Management
An effective QA System requires periodic assessment to determine if the system is operating
as designed and to establish a basis for corrective action. At the organizational level, each
affected organization will be assessed against the appropriate divisional QMP. The RQAM or
designee shall review and evaluate implementation of selected QMPs, including the Region 4
QMP and Region 4 State QMPs.
At the project level, all data collection activities will be assessed against an approved QAPP.
The RQAM or designee shall review and evaluate the implementation of selected QAPPs
during the operational phase of the monitoring activity. Selection of projects will depend on
the following criteria: projects supporting litigation, high visibility projects, and requests from
Project Managers. Upon completion of the project activity, the Project Manager shall assess
the actual performance of the planned activities and subsequent results. The final project
report shall contain the results of this assessment and state whether the data collected meet the
objectives of the project.
The QAPP shall ensure that:
7.1.1 The DQO process or systematic planning process complies with the step-
wise process outlined in EPA's QA/G-4 document.
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7.1.2	The level of data quality required will be determined and stated in terms of
precision, accuracy, completeness, comparability and representativeness, before the
data collection effort begins.
7.1.3	All environmental data generated and processed will be of the quality,
quantity and integrity established by each QAPP or by applicable EPA regulations
as appropriate.
7.2 Types of Assessment
Oversight of the data generation activities in Region 4 will be tailored to the nature of the
activity and the associated management and administrative system. Assessments are the
principal means in Region 4's QA Program to determine compliance with established QA
Management and Project Plans. Several types of assessments are used to verify that
management and measurement systems are operating properly, to assess whether data quality
is adequately documented, and to evaluate the management of QA programs. Detailed
guidance for assessment may be found in Data Quality Assessment: A Reviewer's Guide.
EPA QA/G9R, February 2006. The RQAM has the primary responsibility for conducting
audits at the division and program levels.
Five specific types of assessments will be used at appropriate times by the Region 4 RQAM
to determine whether the Divisional QMPs and Region 4's QMP have been implemented, to
determine the status of measurement systems, the adequacy of the data collection systems, the
completeness of documentation of data collection activities, and the abilities of program
management to meet mandated data collection and data quality objectives. These five audit
types are respectively, program audits, performance audits, technical system audits, data
quality system audits, and management system reviews. These audits are assigned by
managers/supervisorsto staff who have the appropriate experience, training, knowledge and
technical skills. It is the manager's/supervisor's responsibility to ensure auditors assigned for
an assessment have the necessary training and experience to adequately perform the
assessment assigned, that no conflict of interest exists and, whenever possible, they are
independent of the activity to be audited. It is the responsibility of the auditor's
supervisor/manager to review the audit findings to ensure appropriateness and consistency
with EPA policy and guidance. The audit report will be reviewed by the appropriate
supervisor/manager prior to distribution.
Each type of audit is described below:
7.2.1 Program audits are qualitative audits assessing the ability of the programs to
oversee internal operations, and State, Local and Tribal environmental programs to
ensure compliance with EPA regulatory or statutory requirements. Program audits of
the Region 4 states are particularly important since many environmental programs have
been delegated to these entities. Program audits should be conducted every three (3)
years and the findings resulting from the audit, documented and communicated to EPA
program staff, divisional management, and the RQAM. The RQAM and SESD
QATSB/QAS staff will provide additional support to divisional/program staff
conducting the on-site audit to ensure the necessary QA policies and procedures have
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been properly implemented, and the federal, state or tribal regulatory/statutory
requirements met. State and tribal obligations under on-going assistance agreements,
cooperative agreements and other such grants, will also be evaluated during the
program audit to ensure compliance with the terms and conditions of these documents.
7.2.2	Performance audits are quantitative audits of the ability of an analytical system
to obtain reliable data. These audits involve submission of proficiency test (PT)
samples as unknowns to laboratories or other analytical systems. For the most part,
these are part of national program audits such as the Water Supply PT Studies, Water
Pollution PT Studies, DMR QA Studies, Air Intercomparison Studies, etc. These
audits are used as one indicator of the data produced by NPDES Permittees, certified
drinking water laboratories, and Superfund contract laboratories (CLP). The Region 4
SESD laboratory routinely participates in these audits as appropriate. The Region
routinely sends performance samples with each set of samples submitted to the CLP.
Special performance samples are requested by a regional project manager to audit a
laboratory producing data for a potentially responsible party remedial investigation of
a Superfund site or at RCRA facilities.
7.2.3	Technical system audits are on-site environmental assessment activities. The
audits are qualitative assessments of personnel, equipment, facilities, procedures, and
QA activities. These audits are conducted at least biennially at state agencies and
cover ambient air, water quality/water quality enforcement, drinking water, and
hazardous wastes monitoring activities. For monitors used in evaluations of National
Ambient Air Quality Standards, the frequency is specified in 40CFR Part 58
Appendix A as once every three years for each Primary Quality Assurance
Organization (PQAO). Audits (known as Performance Audit Inspections (PAIs)) of
NPDES permittees are conducted routinely in delegated states. PAI candidates are
chosen by EPA and the states; performance in the DMR QA Studies is one of the
criteria used. Other audits are conducted at RCRA facilities and CERCLA
investigations at the request of the program division. The Region 4 SESD laboratory
and field activities are audited every year by the ISO 17025 accrediting authority.
Audits of randomly selected regional activities are conducted as resources permit, or
an activity is audited if there is evidence of inadequate performance.
7.2.4	Data quality audits are quantitative audits in which data are reviewed and
evaluated following collection to determine the quality and usability of the data.
These audits are conducted by SESD QATSB/QAS staff on all CLP data for
CERCLA and any programmatic analytical data which is contracted through SESD.
Data quality audits are performed on data from other sources as requested by the
appropriate project manager or leader.
7.2.5	A management system review (MSR) is an assessment of an organization's
ability to implement and manage an effective QA program. A MSR of the regional
quality system will be conducted every three years. This MSR may consist of a
review of all organizations within the region, or if resources do not permit, of a
selected organization within the region. MSRs also may be conducted of any regional
contractor, or extramural organization which receives funding from the region.
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7.2.6 Annually, the RQAM or designee will:
a.	Randomly select QAPPs that have been reviewed by a one or more of the
divisional DAOs to determine whether they have reviewed the document
in accordance with EPA QA/R-5 requirements and have properly
identified the deficiencies associated with this document. The RQAM
may revoke DAO certification status if non-compliance with any of the
above requirements is encountered or when random review of a DAO's
work product warrants this action.
b.	Conduct internal audits of the QAFAP in accordance with the Region 4
Standard Operating Procedure for Internal Audits and Corrective
Actions, R4PROC-009.
c.	Conduct an evaluation of the implementation of a divisional QMP.
7.3 Corrective Actions
Initially, assessment findings and appropriate corrective actions will be communicated to the
organization's management and staff, as appropriate, during the exit briefing. In some cases,
appropriate corrective actions may be implemented at the time of the exit briefing, especially
if the findings relate to relatively simple issues. A timely report, outlining the findings of the
audit, will be sent to the organization that was audited. The organization will have
approximately 30 calendar days to request clarification of the findings or provide additional
information which has an impact on the findings. After all challenges to the audit findings are
received and reviewed, a final decision will be made by the RQAM and appropriate
managers to resolve the issues identified in the report. If there is no resolution to the
findings, then the assessment findings will be documented and communicated by the RQAM
and provided to the appropriate organizational management official for resolution. If
resolution cannot be reached at lower management levels, the Regional or Deputy Regional
Administrator will be advised of the issues. The final decisions made by the Regional
Administrator or Deputy Regional Administrator will be provided by the RQAM to all
concerned parties. Once a final resolution on the finding is reached, the affected manager
will have approximately 90 calendar days to develop a corrective action plan.
The corrective action plan includes the designation of a corrective action team that will
assess the issues surrounding the nonconformance, determine the root cause of the problem,
and identify feasible corrective actions. Corrective actions shall be commensurate with the
magnitude and the risk of the finding, and depending on the risk associated with the finding,
a corrective action team will be identified. The corrective action plan must be submitted to
the RQAM or designee for review and approval prior to implementation of the selected
corrective action. Corrective actions should be completed within 90 calendar days from
approval. Additional time to implement the corrective action can be requested to the RQAM.
The need for follow-up assessments will be determined by the RQAM and if needed will be
conducted within 6 months to determine if the corrective actions were appropriately
addressed. A follow-up assessment to determine the effectiveness of the implemented action
is especially important for MSR assessments. Corrective actions for Technical and
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Management Assessments will follow the EPA QA/G7 "Guidance on Technical audits and
related Assessments for Environmental Data Operations" Chapter 3, Section 3.5. Corrective
actions and their effectiveness must be documented and the records maintained by the
RQAM or designee.
8.0 DOCUMENTS and RECORDS
The Federal Records Act of 1950, as amended (44 U.S. C. 3101), requires that all Federal
agencies make and preserve records containing adequate and proper documentation of the
organization and its functions, policies, decisions, procedures, and essential transactions.
These records are public property and must be managed according to applicable laws and
regulations. In a Federal Agency, files and records serve as the official memory of the
agency's activities. Records of the agency can be in many forms, formats and storage media.
Because of legal statutes and regulations, all Federal agencies are required to create,
maintain, and retain files, records and information as a valuable resource. All Federal records
are subject to Federal requirements regarding creation, maintenance and retention. These
standards, set by the National Archives and Records Administration (NARA), include
guidelines on the information's ownership, value, and availability.
8.1 Region 4 Records Management System
Region 4 has issued standard operating procedures for managing records. Details of these
procedures are described in documentation prepared by each Division and are based on
identifying the EPA Records Schedule applicable to a document. The standard operating
procedures are based on the following EPA requirements:
•	Records Management Polk \ IO -! ^ r February 10, 2015
This Policy establishes principles, responsibilities and requirements for managing
EPA's records to ensure the Agency is in compliance with federal laws and
regulations, EPA policies and best practices for managing records.
•	Records Schedules
EPA's official policies on how long to keep Agency records (retention) and what to
do with them afterwards (disposition).
•	Essential Records Procedures	March 24, 2015
These procedures prescribe the requirements and responsibilities for establishing and
maintaining EPA's vital records program.
Quality- related records are not managed separately, but are included in the appropriate EPA
Records Retention Schedule. The following general procedures for records management are
in place in Region 4.
8.1.1 Each organizational element (Division or Office) is assigned record
keeping responsibilities in accordance with its functional responsibilities and
duties. Records and information created, received, maintained, or acted upon shall
be maintained in accordance with EPA and NARA approved Records Retention
Schedules.
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8.1.2	Managers and supervisors will be held responsible for ensuring EPA
personnel and contractor staff (working inside or outside EPA) are adhering to
regional, EPA, and NARA record keeping procedures.
8.1.3	Mandatory Records Management training sessions will be provided for all
EPA employees, managers, and contractor staff on record keeping procedures and
FOIA requirements.
8.1.4	Files and agency records may not be checked out to EPA or contractor staff
unless the required records management training courses have been completed.
8.1.5	Files and records may not be checked out for more than 90 days. File check-
out procedures shall be followed by all records personnel. A monthly report shall be
provided to the program management and Regional Records Management of all
records and files removed for more than 90 days. A response will be required from the
program manager for overdue records and files.
8.1.6	A flag in the records circulation system will indicate site files that have been
checked out and not returned for six (6) months or more. This includes files sent to
outside contractor staff. The user will be notified to return files to the records center.
Manager approval is required for site files to be checked out longer than six (6)
months.
8.1.7	A chain of custody form and receipt is required when files are checked out
from the records centers, delivered to an employee and/or contractor staff, and
returned to the record centers. User responsibility for checked out files is established
by this procedure. The user is responsible to ensure the returned files and records are
complete, in proper sequence or order and in the same condition in which received.
8.1.8	EPA employees leaving the agency must return all records to the Records
Center including any records in their workstation that have never been placed in the
Records Center. Supervisors and managers shall be responsible to ensure files and
records are returned.
8.1.9	Files, records and information shall be created, maintained, and retained in
accordance with EPA and the Region's CBI, Privacy, and Vital Record Protection
program requirements.
8.1.10	To improve record reviews and responses to FOIA requests, the Region shall
implement a records system which designates a document as the original or a copy,
provides for a release determination to be made at the time of record creation, and
negates the need for files to be repeatedly reviewed each time a FOIA request is made.
8.1.11	Electronic records and information held in an electronic format shall be
maintained in accordance with approved and issued EPA and NARA guidelines and
retained in accordance with approved Records Retention Schedules.
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8.1.12	Files, records and information shall not be destroyed except in accordance
with EPA and NARA guidelines, requirements and Records Retention Control
Schedules. All destroyed records will have a Certificate of Destruction verifying
destruction in accordance with such guidelines and requirements.
8.1.13	Divisional QMPs must clearly describe the record keeping policies and
procedures for maintaining, archiving, storing, and retrieving documents prepared,
reviewed, revised and approved by EPA.
The Divisional QMPs must also describe the process for:
>	identifying quality related documents and records requiring control;
>	handling documents and records to assure accessibility, protection from
damage and deterioration, and means of retention, including discussion of the
roles and responsibilities of management and staff for implementing the
document control and maintenance policies of the Division;
>	ensuring technical guidance documents are prepared, reviewed, approved,
issued, used, and revised as required by regional QA policy;
>	ensuring compliance with all statutory, contractual, and assistance
agreement requirements for records from environmental programs are
adequately preserved and maintained to support the Division's mission.
8.1.14	All QAPPs, QMPs and other QA documents reviewed by the RQAM and/or
SESD QATSB/QAS are maintained in an electronic database in the Local Area
Network (LAN). Included in the database are the date the document was received,
who conducted the review, the date the memo/report was issued and whether the
document was approved.
9.0 OA COMMUNICATION/REPORTING/WORK PLAN
The purpose of communication is to ensure staff in different programs can effectively develop and
implement programs, perform activities, and resolve problems related to the generation of
environmental data and the use of environmental technology. To effectively implement the regional
quality system, communications must occur between the RQAM and regional managers and staff.
The Office of Environmental Information Enterprise, Quality Management Division (OEIEQMD) is
the primary office for policy and guidance on the Agency's quality system. The RQAM or designee
participates in monthly conference calls with the OEI EQMD and other regional QAMs to be aware
of new or revised QA policies as well as implementation issues associated with the Agency-wide
quality system. Regional requests for assistance, interpretation, and action will be forwarded by the
RQAM to the appropriate OEI EQMD member. The RQAM will exchange QA information with
Region 4 QA Coordinators, Program Managers and staff; EPA laboratories; headquarters' program
offices; and other regions to implement the regional quality system.
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9.1 Regional Communication
The RQAM shall exchange information with Division Directors, Regional Program
Managers, Project Officers, QA Coordinators, Field Quality Coordinators, Technical Staff,
and State/Tribal QA Officers.
9.1.1	A primary means of communication among regional staff is through the
divisional QA Coordinators. The duties and responsibilities of the QA Coordinators are
described in section 3.2.3 of this document.
9.1.2	A primary method of RQAM communication with the State/Tribal QA
community is annual meetings of State/Tribal Laboratory and QA personnel sponsored
by SESD. The State/Tribal QA Officers communicate with appropriate environmental
monitoring personnel, the local Agency QA Officers, and industrial QA Officers.
9.2	QA Annual Report and Work Plan
Each year, the RQAM shall submit a QA Annual Report and Work Plan (QAARWP) to
Region 4 Senior Management and the Director of OEIEQMD. This report shall reflect the
implementation status of the Region 4 QA Program. The QA report will summarize the QA-
related resources, training, accomplishments (i.e., innovative practices, technical assessments,
QMP revisions, QA guidance, technical assistance, etc.) and quality system
assessments/audits that have been conducted in the previous fiscal year. The Work Plan will
also describe all planned QA activities for the fiscal year beginning in October and any other
information required by OEI.
Each division or office that is a part of the Region's Quality System shall provide its
information to be compiled into a Region-wide report. The QAARWP will be prepared
according to Chapter 4 of the most current version of the CIO Procedure 2105-P-01.0
(formerly the EPA Quality Manual, 5360 Al) by the RQAM with cooperation from the QA
Coordinators, Field Quality Coordinators, and SESD Quality Staff (Lab QA Manager, Field
Quality Manager, and SESD QATSB/QAS). Prior to its distribution to the Director of the
EPA OEI EQMD, the report shall be reviewed and approved by the Regional Administrator
or designee.
9.3	National Meetings
In addition to the regular communication/reporting activities described above, the RQAM, or
designee, will participate, at a minimum, in EPA's National QA Conference. The RQAM, or
designee, will participate in other meetings and workgroups, which help to advance national
and regional QA goals and to assist with implementation of the regional quality system.
9.4	Resources
National Program Managers (NPMs) set staffing levels for activities in each of the programs
and regions. In Region 4, distribution of QA-related resources, including Full-Time
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Equivalents (FTEs), are determined by the Regional Administrator and Division Directors.
These senior managers must balance quality system resource needs with other program
resource needs. The SESD Director, with input from the RQAM, will recommend staffing
and resource needs for maintaining the regional quality system.
10.0 PEER REVIEW
Peer review is a documented critical review of specific EPA's major scientific and/or technical work
products. Specifically, peer review is an in-depth assessment of the assumptions, calculations,
extrapolations, alternate interpretations, methodology, acceptance criteria, and conclusions
pertaining to the specific major scientific and/or technical work products and of the documentation
that supports them. Peer review is conducted to ensure activities are technically adequate,
competently performed, properly documented, and satisfy established quality requirements. Peer
review of scientific and technical work products that support decision making actions is an
important, fundamental step for ensuring the decision made or position taken by EPA, based on the
work product, has a sound credible basis.
The U.S. Office of Management and Budget (OMB) issued its bulletin, Final Information Quality
Bulletin for Peer Review, on December 16, 2004, as federal government-wide guidance to enhance
the practice of peer review of government science documents. The bulletin provided guidance to
federal agencies on what information is subject to peer review, selection of appropriate peer
reviewers and opportunities for public participation. Further, the bulletin defined peer review
processes to permit public and scientific societies to contribute to agency dialogue about which
scientific reports merit especially rigorous peer review.
EPA's revised peer review policy Peer Review and Peer Involvement at the U.S. Environmental
Protection Agency, approved by Administrator Stephen Johnson on January 31, 2006, encompasses
scientifically and technically-based work products, including economic and social science products,
that are intended to inform Agency decisions. The U.S. EPA Science and Technology Policy Council
(STPC) Peer Review Handbook, 4th edition (October 2015) provides additional information and
procedures for the implementation of EPA's peer review policy. An overview of EPA's peer review
program including additional references and peer review history may be found at:
http://www.epa.gov/peerreview/. The Region 4 Science Liaison (RSL) is Region 4's Peer Review
Coordinator and will coordinate all Peer Review activities in the Region with the Decision Makers
(Office and Division Directors) and identified Peer Review Leaders in accordance with the Agency's
most recent peer review policy and Peer Review Handbook.
11.0 TRAINING
The RQAM will develop, on an annual basis, a training plan providing the necessary courses to
mitigate targeted deficiencies and vulnerabilities within the Region. Training will be conducted for
QA staff on the basics of a quality system, including training to identify the types of projects that
require a QMP and/or QAPP to meet agency requirements. Technical training in the form of hands-
on sample collection techniques, analytical measurement requirements and data validation and review
will also be offered to regional staff, upon request and depending on the needs. QA or technical
training needs will be identified by supervisors during annual performance evaluations, career
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individual development plans, annual management systems reviews performed by the RQAM or
divisional/program staff, and by QA Coordinators. Supervisors should contact the RQAM to
determine if the identified training needs can be met through regional training provided by the
RQAM/staff, or if other sources are needed for training. The RQAM will assist the supervisor in
locating the most appropriate QA or technical training to meet the need which has been identified.
Results of the technical and QA training needs assessments will be documented and communicated to
Division Directors, Program Managers, and if necessary, the Regional Administrator and the Deputy
Regional Administrator.
11.1 Training Needs Assessments
The training needs of the RQAM and QA staff are not static, but change as the various
environmental programs mature. Therefore, training needs of the RQAM and staff will be
addressed in the Region's annual Quality Assurance Annual Report and Work Plan
(QAARWP). The QAARWP shall be submitted annually to the OEIEQMD Director for
review.
Annually, the RQAM, with assistance from the QAS staff and other SESD organizations, will
present one or more of the following training courses:
•	QA Orientation, Basics of the EPA Quality System
•	Region 4 and Divisional QMP
•	Introduction to the Data Quality Objectives Process,
•	Preparation and Review of QMPs and QAPPs,
•	Data Validation and Verification Procedures for Evaluating
Environmental Data
•	Designated Approving Official Training
•	QA Tracking System
•	QAPP development, requirements and checklists
•	QAFAP Training
•	Training for QAFAP auditors
The SESD QATSB/QAS staff typically schedules two training modules per QA course to
facilitate attendance. Each QA course is offered via webinar or classroom setting at various
times throughout the year. The RQAM is available to discuss specific training needs with
supervisors or staff. Courses may be developed by the RQAM and SESD QATSB/QAS staff
to meet specialized training needs. DAO refresher training is mandatory on an annual basis
and documented in the QA Tracking System.
The RQAM must balance the resources needed to perform programmatic quality assurance
support functions (data verification, performance audits, technical system audits, QAPP
review, etc.) with the resources needed to perform QA training. Although the SESD
QATSB/QAS has limited resources for QA training, the Section's staff continues to provide
technical and QA training to regional personnel, state staff and tribal staff. Due to the lack of
dedicated training resources, the Region currently does not provide QA training to private
sector personnel.
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11.2 Training Records
Each employee is required to maintain training records in accordance with program-specific
requirements. All training records of field employees will be retained in accordance with the
QAFAP and applicable regional and/or program-specific requirements. Training records
shall be maintained in a training folder, in an Agency approved data system [e.g., Field
Readiness Module (FRM), Federal Acquisition Institute Training Application System
(FAITAS), etc.] or in a designated electronic system such as a SharePoint site, One Drive,
etc. All QA training obtained external to the Region will be maintained by the employee,
his/her supervisor, and when appropriate, provided to the RQAM. Training agendas and
attendees of courses provided by the SESD QATSB/QAS and the RQAM will also be
maintained by the RQAM.
12.0 QUALITY IMPROVEMENT
The RQAM implements and makes improvements to the Region 4 quality system when non-
compliance or quality assurance issues are identified by management system reviews, technical
systems reviews, performance evaluations, OEI audits, and communication from regional personnel.
To facilitate improvements to the quality system, the RQAM will conduct meetings with the QA
Coordinators to discuss non-compliance issues and to develop internal policies for communicating
these issues to the appropriate Divisional Directors. The RQAM will also consult with OEI EQMD
to develop strategies forupdating the QMP as improvements are made to the regional quality system.
12.1	Divisional/Program QMPs
To ensure that the requirements specified in this QMP are consistently applied within the
regional divisions and programs, the Divisional QMPs will: (1) specify the management
process for identifying, planning, implementing and evaluating the effectiveness of quality
assurance activities; (2) designate a staff member to coordinate quality improvement; and (3)
require implementation of the corrective action program to ensure conditions adverse to
quality are identified promptly and corrected within a specified time frame.
12.2	Management Systems Assessments/Review
Internal management system reviews will be instituted by the RQAM on an annual basis to
verify the policies and procedures outlined in the Divisional and Regional QMPs have been
implemented and that any corrective actions mandated by the RQAM or the QA
Coordinators have been instituted to mitigate non-compliance with regional QA policies.
The Divisional QA Coordinator and the RQAM may assist in the QA oversight of the
State/Tribal programs during mid-year or annual reviews performed by program staff. During
the initial phase of these on-site QA assessments, grants, extramural agreements and
interagency agreements will be targeted to determine whether the appropriate QA measures
and requirements specified in the assistance agreement documents have been met.
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12.3 Quality Assurance Training
As part of the quality improvement process, the RQAM will conduct an internal QA training
needs assessment annually to identify areas of vulnerability. QA training will focus on CIO
2105.0, the Region 4 QMP, Divisional QMPs, preparation of QMPs and QAPPs,
development of DQOs, DAOs, and data quality assessments, and data validation. If the
RQAM determines that the SESD QATSB/QAS personnel are not able to provide additional
training, external training sources will be sought.
The RQAM will determine the effectiveness of the training provided to regional staff by
conducting MSRs, by reviewing the quality of the work products, and by evaluating
divisional work processes. When problems are noted by the RQAM through this exercise, a
corrective action report identifying additional training needs will be developed in accordance
with Section 7.3.
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APPENDIX A
REGION 4 ORGANIZATIONAL CHARTS
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Region 4 Office of the Regional Administrator
08/06/2018
Office of the Regional Administrator
On is "Trey" Glenn
Regional Administrator
Mary S. Walker
Deputy Regional Administrator
Blake Ash bee
Chief of Staff
Office of External Affairs
Larry Lincoln, Director
Office of Government Relations
Allison Wise, Director
Water Protection Division
Office of Environmental Justice and
Sustainability
Denise Tennessee, Director
Jeaneanne Gettle, Director
Cesar Zapata, Deputy Director
Becky Allenbach, Deputy Director
Office of Enforcement Coordination
J. Scott Gordon, Director
Administrative Assistant to the
Chief of Staff
Vacant
Executive Assistant to the DRA
Belinda Johnson
Special Assistant to the DRA
Shea Jones-Johnson
Executive Assistant to the RA
Wanda Hudson
Special Assistant to the RA
Brandi Jenkins
Science Liaison to ORD
Dawn "faylor
Agriculture Coordinator
Vacant
Academic Institutions Coordinator
Vacant
Tribal Relations Coordinator
5uzanne Armor, Acting
College Underserved Community
Partnership Programs (CUPP) Coordinator
Michael Burns
Office of Policy & Management
Kristy Eubanks, Acting ARA
Keith R. Mills, Acting Deputy ARA
Air, Pesticides & Toxics
Management Division
Beverly H. Banister, Director
Carol Kemker, Deputy Director
Ken Mitchell, Deputy Director
Leif Palmer, Regional Counsel
& Director
Suzanne Rubini, Deputy Regional Counsel
Office of Regional Counsel
Science & Ecosystem Support Division
Vickie Tellis, Acting Director
Danny France, Acting Deputy Director
RCR Division
Carol Monell, Acting Director
Ramon Torres, Acting Deputy Director
Gulf of Mexico Program
LaKeshia Robertson, Acting Director
Vacant, Deputy Director
Superfund Division
Franklin Hill, Director
Randall Chaffins, Deputy Director
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Region 4 Air, Pesticides and Toxics Management Division
I	I Regional Administrator
»	i Other Significant Office/Position
I	I Division
i	i Office
»	i Branch
'	' Section
6/15/2018
South Air Enforcement and
Toxics Section
Todd Russo, Chief
Air Data & Analysis
Section
Todd Rinck, Chief
Communities Support
Section
Amber Davis, Chief
North Air Enforcement
and Toxics Section
Richard S. Dubose, Chief
Lead and Asbestos
Section
Donnette Sturdivant, Chief
Pesticides Section
Kimberly Bingham, Chief
Air Regulatory
Management Section
Lynorae Benjamin, Chief
Air Permitting Section
Heather Ceron, Chief
Chemical Management
and Emergency
Planning Section
Robert Bookman, Chief
Air Planning and
Implementation Branch
R. Scott Davis III, Chief
Air Enforcement and
Toxics Branch
Beverly Spagg, Chief
Chemical Safety and
Enforcement Branch
Anthony Toney, Chief
Air Analysis and
Support Branch
Gregg Worley, Chief
Grants Management and
Strategic Planning Office
Stuart Perry, Chief
Air, Pesticides & Toxics Management Division
Beverly H. Banister, Director
Carol L. Kemker, Deputy Director
Ken Mitchell, Deputy Director
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Region 4 Office of Policy and Management
Assistant Regional Administrator (ARA)
(Acting) Khsty Eubaitks
Acting, Deputy ARA
Keith R. Mills
08/17/2018
Office of Civil Rights
Acting, E£Q Manager
Veronica Robertson
Office of Human Capital
Management
Rhonda Bailey, Chief
Information Management
Integration Team
Planning & Business
Operations Section
Angle Btllups, Chief
Freedom of Information Act Si
	 Records Management Section
Lou Ann Gross, Chief
Acquisition Management
Section
Michael Pug ram. Chief
Grants and Audit Management
Section
Kcva Lloyd, Chief
Cost Recovery Team
Sarah Rodr»guez-Franco
Team Lead
Budget & Finance Section
Kim Walton, Acting Chief
Facilities & Environmental
Solutions Services Section
Donald G. Fortson
Rickey Felton, Acting Chief
Information Technology
Support Services Section
Facilities, Grants & Acquisitions
Management Branch
Iris Ashrncade, Chief
Business Operations & Financial
Management Branch
Pareasa Stevens, Acting Chief
Information Systems &
Management
Branch
Donald Westra, Acting Chief
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Region 4 Office of Regional Counsel
08/16/2018

Office of Regional Counsel
¦>

Leif Palmer


Regional Counsel


Suzanne Rublnl


Deputy Regional Counsel

3 Regional D rector
3 Cther S^nltfcant Gfficcv'FQJtton
3C«ce
3t>Wdi
3 Sector
Office of Water Legal
Support
Mita Ghosh, Chief
Office of Air, Pesticides &.
Toxics Legal Support
Valerie Nowell, Chief
Office of General Law/
Criminal Law/ Cross-Office
Support
	Vacant. Chief	
Office of CERCLA Legal
Support
David Clay, Chief
Office of CERCLA/Federal
Facilities Legal Support
Mary C. Johnson, Chief
Office of RCRA/CERCLA
Legal Support
Susan Hansen, Chief
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Gulf of Mexico Program
Program Analyst
Life Scientist
(Vacant)
Environmental Engineer
Environmental Engineer
Environmental Engineer
PhysicalScientist
Physical Scientist
Physical Scientist
Managements Program
Analyst
Program Analyst
Environmental Protection
Specialist
Chief of Staff
Acting Director
LaKeshia Robertson
Budget and Human
Resources
Science, Integration &
AnalysisTeam Lead
Troy Pierce
Partnerships Team
[Vacant)
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Region 4 Resource Conservation and Restoration Division
Resource Conservation and Restoration Division
FusoiGnal binct&r
Ottlfr Sirinilirint Dfflr«j'Po«ltinn
January 26, 2018
Carol MoneiL Acting, Director
Ramon Torres, Acting, Deputy Director
Brownfielcis Section
Cindy Nolan, Chief
PCB Cleanup and
Approval Tea mi
Leader
Ken Feely
Corrective Action Section
Vacant, Chief
UST & PCB/OPA
Enforcement and
Compliance Section
Bill Truman, Chtef
RCRA Cleanup and
Brownfields Branch
Bill Denman, Chief
Materials and Waste
Management Branch
Meredith Anderson, Chief
National Environmental
Policy Act Office
ChrlsMllitscher
Ha^arduui Waste Enforcement
And Compliance Section
Alan Annlcella, Chief
RCRA Programs and
Materials Management
Section
Dee Rodqer^-Smith,
Chief
Enforcement and
Compliance Branch-Vacant
Larry Lamberth, Chief
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Superfund Division Organization
Superfund Division
Franklin E. Hill, Director
(404) 562-8599/(404) 218-9207
Randall Chaffins, Deputy Director
(404)562-8910/(404) 307-3076
VACANT, Associate Director
Emergency Response,
Removal & Prevention
James Webster, Branch Chief
<404) 562-8769 f (404) 909 2 590
Removal & 041 Programs
Jim McGwire, Section Chief
(404| 562-8911 /(678) ?964>09?
Removal Operations
Matt Taylor, Section Chief
(404) 562-8759 / (404) 434-8859
Emergency Response
Tony Moore, Section Chief
1404) 562-8756/|404f 229-8902
Restoration &
Site Evaluation
VACANT
Restoration & Investigation
Nestor Young, Section C hi<-f
(404) *62-8812 / (404) 791-1527
Restoration &
Sustainabllity
Caroline liwnun, Bunch Chief
(404) 562 8976 / (404) 754-1736
Restoration &
DOE Coordination
Rkhaid Campbell, Section Chief
(404) 562-8825 / (404) 769-2611
Restoration & Site Evaluation
Meiedith Clark, Section Chief
(404) 562-8919 / (404) 640 3990
Resource &
Scientific Integrity
David Keefer, Branch Chief
(404) 562-8932 / (404) 433-1212
Restoration & Construction
Dciek Mdtory, Section Chief
(404) 562-8800 / (404) 769-5609
Restoration &
DOO Coordination
Mkhele Thornton, Section Chief
(404) 562 8526 / (404)431-1231
Restoration &
Sustalnablllty
Enforcement & Community
Engagement
Maurice Honey, Bunch Chief
(404) 562 9764 / (470) 259-2555
Resource Management
VACANT
Scientific Support
Glenn Adams, Section Ch ief
(404) 562-8771 / (404) 229-9508
investigations & Community
Engagement
Rac he I McCu Hough, Section Chief
(404)562 8549 / (404) 955-4470
Enforcement
Greg Armstrong, Section Chief
(404) 562-8872 / (404) 617-9253
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Region 4 Water Protection Division
ysemtr^

Water Protection Division
61 Forsyth Street, SW Atlanta, GA 30303-8960
Telephone: 404-562-9345 Fax: 404-562-9318
Jeaneanne M. Gettle, Director
404-562-8979
Pam Marcus, Secretary
404-562-9372
Cesar A. Zapata. Deputy Director
404-562-9744
Becky Allenbach, Deputy Director
404-562-9687

NPDES Permitting and
Enforcement Branch
Telephone: 404-562-9724
Fax: 404-562-9729
Gracy Danots, Acting Chief
404-562-9119
Vacant Staff Assistant
404-562-####
Municipal and Industrial
Enforcement Section
David Apanian, Acting Chief
404-562-9477
Stormwater and Residuals
Enforcement Section
Mark Robertson, Acting Chief
404-562-9639
NPDES Permitting Section
Molly Davis, Chief
404-562-9236
r Ocean, Wetlands and ^
Streams Protection Branch
Telephone: 404-562-9355
Fax: 404-562-9343
Thomas McGill, Chief
404-562-9243
Vacant
Staff Assistant
404-562-####
Marine Regulatory and Wetlands
Enforcement Section
Jennifer Derby, Chief
404-562-9401
Wetlands and Streams
Regulatory Section
Johnnie Purify, Acting Chief
404-562-9298
^^Graiit^n^rinkin^l
Water Protection Branch
Telephone: 404-562-9424
Fax: 404-562-9439
Brian Smith, Acting Chief
404-562-9645
Annette Jones, Staff Assistant
404-562-9737
Drinking Water Section
Shawneille Campbell-Diribar, Chief
404-562-9324
Ground Water and UIC Section
Alanna Conley, Acting Chief
404-562-9768
Grants and Infrastructure Section
Stacey Bouma. Chief
404-562-9392
Water Quality
Planning Branch
Telephone: 404-562-9250
Fax: 404-562-9224
Tony Ab6e, Acting Chief
404-562-9273
Carmen Point-Kelly
Secretary
404-562-9226
Water Quality Standards
Section
Lisa Gordon, Acting Chief
404-562-9317
Data and Information
Analysis Section
Amanda Howell, Acting Chief
404-562-8017
Assessment, Listing, and
TMDL Section
Joel Hansel. Acting Chief
404-562-9274
bustainal^
and Watersheds Branch
Telephone: 404-562-9984
Fax: 404-562-8692
Chris Thomas, Chief
404-562-9459

Vacant
Staff Assistant
404-562-####
Eastern Communities and
Watersheds Section
Mailt Nuhfer, Chief
404-562-9390
Western Communities and
Watersheds Section
Natalie Ellington. Chief
404-562-9453
EPA's e-mail uses the following format: last name.first name@epa.gov
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Science and Ecosystem Support Division
Athens, Georgia
Immediate Office
Director
Vickie Tell is (Acting)
(706) 355-8549
Deputy Director
Danny France
(706) 355-8738
Field Service
Branch Chief
John Deatrick
(706) 355-8774
r ^
Enforcement Section
r
Superfund and Air
Mike Bowden, Chief
Section
(706) 355-8734
L. ^
Laura Acker man. Chief
(706) 355-8776
k. J
Analytical Services
Branch Chief
•Vacant
(706) 355-
Program Support Section
Hunter Johnson
(706) 355-8722
Quality Assurance Section
Sandra Aker
(706) 355-8772
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Region 4 Quality Assurance Management
	1
Quality Assurance and Technical Services Branch
Denisse Diaz, Chief
Liza Montalvo, RQAM
Mary S. Walker
Deputy Regional Administrator
Onis "Trey" Glenn
Regional Administrator
Science and Ecosystem Support Division
Vickie H. Tellis, Acting Director
Danny France, Deputy Director
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APPENDIX B
REGION 4
MAJOR PROGRAM ELEMENTS
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ACTIVITY
APPLICABLE
LAW
RESPONSIBLE
DIVISION
SESD BRANCH
PROVIDING
SUPPORT
Ambient Air Monitoring for Criteria
Pollutants — Delegated to the states. The Region
has an overview/ technical assistance role.
Special studies (i.e., Air Toxics) are conducted to
support state programs.
CAA
APTMD
FSB, ASB
Stationary Source Enforcement — Delegated to
the states. The Region has an overview/technical
assistance role.
CAA
APTMD
FSB, ASB
Mobile Source Inspections and Maintenance
— Delegated to the states. The Region has an
overview/ technical assistance role.
CAA
APTMD
FSB, ASB
Pesticide Use/Misuses — Delegated to the states.
The Region has an overview/ technical assistance
role. The states regulate and monitor the
manufacture, sale, and use of pesticides.
FIFRA
APTMD
FSB, ASB,
QATSB/QAS
PCB and Dioxin Inspections — Inspections are
conducted at transformer stations, substations,
etc. Program inspectors conduct sampling;
analyses are conducted by SESD and contract
laboratories.
TSCA
APTMD
FSB, ASB
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ACTIVITY
APPLICABLE
LAW
RESPONSIBLE
DIVISION
SESD BRANCH
PROVIDING
SUPPORT
Asbestos Inspections — Overview of asbestos
removal from schools and overview of renovation
and demolition of buildings.
Sampling and analyses are conducted by
contractors.
TSCA
APTMD
QATSB/QAS
Water Quality Monitoring — Most programs
delegated to the states. Activities involve both fixed
station networks and intensive studies.
The Region has an overview/technical assistance
role which includes special studies to support state
programs.
CWA
WPD
FSB,
QATSB/QAS
Water Quality Enforcement — Delegated to all
states. Several types of compliance inspections are
conducted as overview for delegated states.
CWA
WPD
FSB,
QATSB/QAS
Dredge and Fill - Investigations are conducted by
SESD to support permitting decisions by the
Region and for enforcement actions by the
Department of Justice.
CWA
WPD
FSB,
QATSB/QAS
RCRA Enforcement — The program is delegated
to the states. Several types of inspections are
conducted by SESD and contractors. These include
inspections of generators, transporters, and disposal
facilities.
RCRA
RCRD
FSB,
QATSB/QAS
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ACTIVITY
APPLICABLE
LAW
RESPONSIBLE
DIVISION
SESD BRANCH
PROVIDING
SUPPORT
Investigations of Uncontrolled Hazardous
Waste Site — Several types of investigations are
conducted to support listing of sites on the NPL
and for remedial actions (immediate removal or
clean-up activities). Investigations are conducted
by contractors, states under cooperative
agreements, potentially responsible parties under
consent orders and SESD. The Region overviews
all extramural investigations.
CERCLA
Superfund
Division
FSB,
QATSB/QAS
Monitoring of Public Water Supplies —
Program is delegated to the states. The Region
has an overview/technical assistance role.
SESD conducts special studies in support of state
programs.
SDWA
WPD
FSB,
QATSB/QAS
Underground Injection Control — Program is
delegated to the states. The Region has an
overview/technical assistance role. SESD
conducts special studies in support of the state
programs.
SDWA
WPD
FSB
Investigations of Leaking Underground
Storage Tanks — The RCRA program (UST) is
delegated to the states. The Region has primary
responsibility for the UST program in Georgia
and overviews the other seven state programs.
RCRA
RCRD
FSB
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APPENDIX C
REGION 4
QUALITY MANAGEMENT PLAN CHECKLIST
QUALITY ASSURANCE PROJECT PLAN
CHECKLIST
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Region 4 Quality Management Plan Review Checklist - Revised March 2011
Title:
Organization:
QMP Date:
Received Date:
Review Date:
Reviewer:
Region 4 Quality Assurance Section
Quality Management Plan Checklist
Key: P=Present & Acceptable; NP=Not Present; I=Incomplete; NA=Not Applicable
ELEMENT
COMMENTS
(1) Management and Organization

1.1 Provides Title Page, Approval Page, Table of Contents,
References- Approval Page includes signatures of senior
management and the Quality Assurance Manager/Officer

1.2 Summarizes the importance of QA and QC activities to the
organization

1.3 Describes the general goals and objectives of the quality
system

1.4 Summarizes the policy for resource allocation for the
quality system

1.5 Contains a reasonable organizational structure with respect
to roles/responsibilities described in narrative & includes an
organizational chart

1.6 QA Manager is included in the organizational chart

1.7 Demonstrates direct access from the QA Manager to senior
organization manager - explains how the organization will
ensure that QA personnel will have access to the appropriate
levels of management to plan, assess and improve the
organization's quality system

1.8 Describes QA Manager's independence and authority with
respect to decisions on data quality

1.9 QA policy statement which demonstrates importance of
environmental data in organizational decision-making

1.10 Adequately describes the scope of the organization's
environmental data collection programs which require quality
management

1.11 Discusses process for oversight of contractor activities (if
data collection/analysis is contracted outside the agency)

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1.12 Provides a discussion of the technical activities or
programs that are supported by the quality system

1.13 Identifies the specific programs or activities that require
quality management controls

1.14 Identifies where oversight of delegated, contracted or other
extramural programs is needed to assure data quality

ELEMENT
COMMENTS
1.15 Where and how internal coordination of QA and QC
activities among the group's organizational units needs to occur

1.16 Describes how management will assure that applicable
elements of the quality system are understood and implemented
in all environmental programs

1.17 Discusses the organization's process for resolving disputes
regarding quality system requirements, QA and QC procedures,
assessments, or corrective actions,

(2) Quality System and Description

2.1 Describes the main components of the quality system,
including quality system documentation, planning, annual
reviews, management assessments, training, systematic project
planning, project-specific documentation, project and data
assessments

2.2 Discusses staff and management roles and responsibilities
for quality assurance in environmental programs and for
QA/QC in data collection

2.3 Provides a list of tools for implementing each component of
the quality system. Tools include Quality Management Plan,
Quality System Audits, Training Plans (for technical and
quality assurance training), Quality Assurance Project Plan,
Data Verification and Validation

2.4 Provides a list of the environmental programs that develop
Quality Management Plans in support of the Quality System

2.5 Describes the process for reviewing and approving internal
Quality Management Plans within the organization

2.6 Describes the process for implementing QA/QC activities
within the organization

2.7 Describes the roles and responsibilities of contractors or
consultants in implementing the organization's quality system

(3) Personnel Qualifications and Training

3.1 Provides a policy statement regarding QA and technical
training for staff and management

3.2 Describes the process for assuring that personnel are
qualified to perform the environmental data collection activities

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- identifies positions that require professional certifications,
accreditation or other formal qualifications

3.3 Describes the procedures for determining QA-related
training needs; discusses how QA training is obtained; and
describes how the effectiveness of the QA training obtained is
measured

3.4 Identifies the roles and responsibilities of management and
authorities for obtaining QA training within the organization

Key: P=Present & Acceptable; NP=Not Present; I=Incomplete; NA=Not Applicable
ELEMENT
COMMENTS
(4) Procurement of Items and Services

4.1 Describes the roles and responsibilities of management and
staff for reviewing and approving procurement documents to
ensure that they are accurate and complete

4.2 Discusses the process for ensuring that procurement
documents clearly describe the items and services needed;
include the associated technical and quality requirements,
identifies the quality system elements for which the supplier is
responsible for adhering to; and discusses how the supplier's
conformance to the customer's requirements are verified

4.3 Describes the process for specifying QA and QC
requirements in purchase orders, procurement documents,
acquisitions and assistance agreements

4.4 Identifies the individual(s) who are responsible for
overseeing this process

4.5 Describes the procedures for incorporating QA and QC
requirements into contractor work assignments, technical
directives, etc.

(5) Documents and Records

5.1 Describes the processes, including the roles and
responsibilities, and authorities of management and staff for:
identifying quality related documents and records (including
hardcopy and electronic formats) requiring control

5.2 Identifies the individual(s) who are responsible for
preparing and reviewing documents for conformance to
technical and quality system requirements

5.3 Discusses the process for approving, issuing, using,
authenticating, and revising documents and records

5.4 Identifies the individual responsible for ensuring that
records and documents accurately reflect completed work

5.5 Describes the policies and procedures for maintaining
documents and records including transmittal, distribution,
retention (specifies retention time for documents and records),

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access, preservation (including protection from damage, loss
and deterioration), traceability, retrieval, removal of obsolete
documentation, and disposition.

5.6 Identifies the individual and policies for ensuring that
documents and records comply with all applicable regulatory,
statutory, and EPA requirements

5.7 Describes the procedures and identifies the individuals
responsible for establishing and implementing appropriate
chain-of-custody and confidentiality procedures for evidentiary
records

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Key: P=Present & Acceptable; NP=Not Present; I=Incomplete; NA=Not Applicable
ELEMENT
COMMENTS
(6) Computer Hardware and Software

6.1 Describes the processes, including the roles, responsibilities
and authorities of management and staff for developing,
installing, testing, using, maintaining, controlling, and
documenting computer hardware and software used in
environmental programs to ensure compliance with technical
and quality system requirements

6.2 Describes the procedures for assessing and documenting the
impact of changes to user requirements

6.3 Discusses the process for evaluating purchased hardware
and software to ensure it meets user requirements and complies
with applicable contractual requirements and standards

6.4 Describes the process for ensuring that data and information
produced from or collected by, computers meet applicable
information resource management requirements and standards

6.5 Describes the process for identifying and documenting the
quality of environmental data in data bases and information
systems - identifies the individual(s) responsible for certifying
that data bases and information systems contain accurate
information

(7) Planning

7.1 Describes the process for planning environmental data
collection operations

7.2 Identifies the roles and responsibilities of management and
staff in the planning - discusses the involvement of project
managers, sponsoring organization, project personnel, scientific
experts, stakeholders and end data users

7.3 Identifies how technical expertise in sampling, statistics,
analytical services and QA/QC is provided

7.4 Describes the use of a systematic planning process or data
quality objectives process in planning environmental data
collection operations

7.5 Discussed the procedures for measuring the effectiveness of
the planning process by management

7.6 Describes the process for determining the type, quantity and
quality of data to ensure that this information meets project
objectives

7.7 Describes the process for preparing, reviewing and
approving QA project plans for environmental data collection
operations performed by the organization

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7.8 Describes the process for preparing, reviewing and
approving QA project plans for environmental data collection
operations performed by contractors/consultants or assistance
agreement holders

Key: P=Present & Acceptable; NP=Not Present; I=Incomplete; NA=Not Applicable
ELEMENT
COMMENTS
(8) Implementation of Work Processes

8.1 Describes the process used for implementing QA Project
Plans or other planning documentation for environmental data
collection operations

8.2 Discusses the system used to assure that such
implementation is accomplished properly

8.3 Describes how revisions to QA Project Plans and/or other
planning documents are made, maintained and communicated
to all parties involved (project personnel, stakeholders and end
data users, etc.)

(9) Assessment and Response

9.1 Discusses how the adequacy of the quality system is
assessed (audits, peer reviews, surveillance, readiness reviews,
performance evaluations, etc.) annually and identifies the
individual responsible for performing this assessment

9.2 Describes the authority, competence, experience and
training necessary to ensure that personnel conducting
assessments or audits are technically knowledgeable, have no
real or perceived conflict of interest, and have no direct
involvement or responsibility for the work being assessed

9.3 Discusses the process for planning, conducting and
reporting the results of assessment activities

9.4 Discusses management's responsibility for reviewing and
responding to assessment or audit findings

9.5 Discusses how and when corrective actions will be
implemented in response to audit/assessment findings

9.6 Identifies the individual(s) who are responsible for
addressing any disputes arising from audits/assessments

(10) Quality Improvement

10.1 Identifies who is responsible for identifying, planning,
implementing and evaluating the effectiveness of quality
improvement activities

10.2 Describes the process for ensuring the continued
improvement of the quality system

10.3 Describes the process for ensuring that conditions adverse
to quality are prevented, identified promptly and corrected as
soon as possible

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10.4 Discusses how corrective actions are documented, tracked
completed and verified

References: Includes a reference section that identifies all of
the documents used in QMP preparation and / or cited in the
QMP.

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Final QMP Disposition:
	Approved, no comments
	Not Approved, Address Comments, Submit Revised QMP to EPA for Final
Review and Approval
References.
EPA Requirements for Quality Management Plans. EPA QA/R-2, EPA/240/B-01/002
(March 2001)
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Region 4 QAPP Review Checklist
Version 1.1 - Revised March 29, 2007
REGION 4 QAPP REVIEW CHECKLIST
P= Present & Acceptable; NP = Not Present; I = Incomplete; NA = Not Applicable
QAPP Title:
Project Location:
Originating Organization:
Receipt Date:
Review Date:
Reviewer:
Project Number:
USEPA
REGION 4 QUALITY ASSURANCE SECTION
QAPP REVIEW CHECKLIST
P=Present & Acceptable; NP=Not Present; I=Incomplete; NA=Not Applicable
ELEMENT
COMMENTS
Al. Title and Approval Sheet

Title

Organization's Name

Dated Signature of Project Manager

Dated Signature of Quality Assurance Officer

A2. Table of Contents

A3. Distribution List

A4. Project/Task Organization

Identifies key project personnel, with their roles and

Responsibilities well defined (includes end data users -
project QA manager, subcontractors, etc).

A5. Problem Definition/Background

Clearly states problems or decision to be made

Provides historical and background information

A6. Project/Task Description

Lists measurements to be made includes on-site field analysis
and off-site fixed laboratory analysis

Cites applicable technical, regulatory, or program-specific
standards, criteria, or objectives

Identifies types of personnel, equipment and instruments
required to perform field sampling, field analysis and laboratory
analysis

Provides work schedule and data deliverable timelines

Summarizes required project and QA records/reports

A7. Objectives and Criteria for Measurement Data

State project objectives - quantitatively and quantitatively

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Links measurement quality objectives to applicable action
limits, criteria, etc.

REGION 4 QAPP REVIEW CHECKLIST (Continued)
P=Present & Acceptable; NP=Not Present; I=Incomplete; NA=Not Applicable
ELEMENT
COMMENTS
A8. Special Training Requirements/Certified Listed

States how training is provided, documented and assured

A9. Documentation and Records

Lists information and records to be included in data report (e.g.,
raw data, field logs, results of QC checks, problems
encountered

Specifies the turnaround time for laboratory data deliverables

Specifies the retention time and location for project records and
reports

Bl. Sampling Process Design (Rational for Design)

Specified the type, number and matrix of samples slated for
collection

Discusses the rationale for the proposed sampling design

Specifies sample locations and frequency of sample collection
at each location

B2. Sampling Methods Requirements

Describes sample collection procedures and methods

Lists equipment needs

Identifies support facilities

Identifies individuals responsible for corrective actions in the
field

Describes the process for preparation and decontamination of
sampling equipment

Describes selection and preparation of sample containers - and
specifies sample volumes

Describes sample container, volume, preservation and holding
time requirements per each chemical, physical or biological
parameter

B3. Sample Handling and Custody Requirements

Summarizes sample handling requirements

Summarizes chain-of-custody procedures

B4. Analytical Methods Requirements

Identifies the analytical methods to be followed (including
method number - and sample preparation method such as
digestion/extraction method where applicable)

Provides validation information for non-standard methods

Identifies individuals responsible for corrective action

Specifies the laboratory turnaround time for analysis and data
deliverables

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REGION 4 QAPP REVIEW CHECKLIST (Continued)
P=Present & Acceptable; NP=Not Present; I=Incomplete; NA=Not Applicable
ELEMENT
COMMENTS
B5. Quality Control Requirements

Identifies QC procedures and frequency for each sampling
event, analysis, or measurement technique, as well as associated
acceptance criteria and corrective actions

References procedures and provides equations for calculating
QC statistics including bias/accuracy, precision - specifies
acceptance criteria for completeness, comparability and
representativeness

B6. Instrument/Equipment Testing, Inspection and
Maintenance Requirements

Identifies acceptance testing of sampling and measurement
systems

Describes equipment preventive and corrective maintenance

Summarizes availability and location of spare parts

B7. Instrument Calibration and Frequency

Identifies equipment needing calibration and frequency for
such calibration

Summarizes required calibration standards, gases and/or
equipment

Cites calibration records and the manner traceable to equipment

B8. Inspection/Acceptance Requirements for Supplies and
Consumables

Provides a list of the supplies and consumables including pH
buffers, conductivity and turbidity standards, etc.

States acceptance criteria for supplies and consumables

Identifies the individuals responsible for inspecting supplies and
consumables to ensure compliance with requirements

B9. Data Acquisition Requirements for Non-Direct
Measurements

Identifies type of data needed from non-measurement sources
(e.g., computer databases, literature searches, models, etc.) and
provides the acceptance criteria for using this information

Describes the limitations of this information and specifies when
and when it cannot be used

Documents the rationale for original collection of data and its
relevance to the project

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REGION 4 QAPP REVIEW CHECKLIST (Continued)
P=Present & Acceptable; NP=Not Present; I=Incomplete; NA=Not Applicable
ELEMENT
COMMENTS
BIO. Data Management

Describes record/data keeping, storage and retrieval
policies/requirements for organization/project

Provides attachments to the QAPP containing SOPs, Checklists,
Analytical Methodologies, etc.

Describes data handling equipment and procedures used to
process, compile and analyze data (e.g., computer hardware and
software) - identifies the type of software used such as Excel,
Statistical, Data Validation, etc.

Describes the process for assuring that applicable Office of
Information Resource requirements are satisfied.

CI. Assessments and Response Actions

Lists the required number, frequency and type of assessments
or audits complete with dates and names of auditors/personnel
conducting these assessments (assessments can include
management system reviews, technical systems reviews, peer
reviews, surveillance, performance evaluation audits, laboratory
audits, data quality audits, etc.)

Describes the process for planning audits and assessments and
identifies the individuals that participate in this planning

Identifies those individuals responsible for performing audits
and assessments

Specifies the auditor's independence, authority and competence
in performing audits/assessments

Specifies how audit findings are documented, verified and
communicated to project personnel, senior management and
EPA

Identifies individual(s) responsible for implementing corrective
actions

C2. Reports to Management

Identifies the frequency and distribution of reports for:

Project Status Reports

Results of Performance Evaluations and Audits

Results of periodic data quality assessments

Results of quality assurance problems

Identifies those individuals responsible for preparing reports
and those that will receive these items

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REGION 4 QAPP REVIEW CHECKLIST (Continued)
P=Present & Acceptable; NP=Not Present; I=Incomplete; NA=Not Applicable
ELEMENT
COMMENTS
D1. Data Review, Validation and Verification

Specifies criteria for accepting, rejecting or qualifying data

Provides a list of data qualifier flags and provides definition of
each flag

Provides project-specific statistics, calculations or algorithms

D2. Validation and Verification Methods

Describes or provides the data validation and verification
process (can provide validation SOPs)

Describe resolution procedures for data quality problems and
identifies individuals responsible for resoling data quality
issues

Describes the procedures for documenting the results of data
validation, review and verification

Describes the process for communicating data validation results
to project personnel

D3. Reconciliation of Data to Project Objectives

Describes the process for reconciling project results with the
project-specific data quality objectives and identifies the
limitations of the data

Specifies the usability of the data and verifies that it meets
project objectives

Identifies the individuals who are responsible for reconciling
the data to the project data quality objectives

References: Includes a reference section that identifies all of the
documents used in QMP preparation and / or cited in the QMP.

Final QAPP Disposition:
	Approved, no comments
	Not Approved, Address Comments, Submit Revised QAPP to EPA PO
References
1.	EPA Requirements for Quality Assurance Project Plans. EPA QA/R-5, EPA/240/B-01/002
(March 2001).
2.	EPA Guidance on Systematic Planning Using the Data Quality Objectives Process. EPA
QA/G-4, EPA/240/B-06/001 (February 2006).
Both documents can be accessed at the following website: www.epa.gov/qualitv - Select guidance
from the menu options to the left of the screen.
Region 4 Quality Management Plan
Page 79 of 79
R4QMP-001-082018

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