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Model QA Project Plan



                       General Instructions


      PLEASE READ THIS PAGE BEFORE USING THE MODEL QAPP!!


     1) Consult EPA QA/R-5, "EPA Requirement for Quality
     Assurance Project Plans for Environmental Data Operations"
     and EPA QA/G-5 "EPA Guidance for Quality Assurance Project
     Plans" before preparing a QAPP.

     2) This model QAPP is based on an example Superfund site and
     should be used as guidance for the preparation of a QAPP.
     Remember that some elements and SOP references may not apply
     to your project or you may need to include additional
     information not found here.  If an element does not apply to
     your project, this must be clearly stated in the QAPP.

     3) The bold text indicates "boilerplate" language which may
     be used in QAPPs prepared for Region 7 projects if the Sops
     and procedures included in the boilerplate language will be
     used for your project.





                  Quality Assurance Project Plan
                             for the
                      Rawhide Superfund Site
                          Any town, USA






                   prepared by Contractors-R-Us
                           October 1996












____________________________________         _________________
Contractors-R-Us Project Manager             Date


____________________________________         _________________              
Contractors-R-Us QA Manager                  Date


____________________________________         _________________              
EPA Project Manager                          Date


____________________________________         ________________
EPA Project Manager Supervisor               Date


____________________________________         _________________
EPA QA Manger                                Date





                        Table of Contents


A.  Project Management . . . . . . . . . . . . . . . . . . . . .3
     A3.  Distribution List. . . . . . . . . . . . . . . . . . .3
     A4.  Project/Task Organization. . . . . . . . . . . . . . .3
     A5.  Problem Definition/Background. . . . . . . . . . . . .3
     A6.  Project/Task Description . . . . . . . . . . . . . . .4
     A7.  Quality Objectives and Criteria for Measurement Data .5
     A9.  Special Training Requirements/Certification. . . . . .5
     A10.  Documentation and Records . . . . . . . . . . . . . .5

B.  Measurement/Data Acquisition . . . . . . . . . . . . . . . .6
     Be.  Sampling Process Design. . . . . . . . . . . . . . . .6
     B2.  Sampling Methods Requirements. . . . . . . . . . . . .6
     B3.  Sample Handling and Custody Requirements . . . . . . .6
     B4.  Analytical Methods Requirements. . . . . . . . . . . .7
     B5. Quality Control Requirements. . . . . . . . . . . . . .7
     B6.  Instrument/Equipment Testing, Inspection, and
          Maintenance Requirements . . . . . . . . . . . . . . .7
     B7.  Instrument Calibration and Frequency . . . . . . . . .7
     B8.  Inspection/Acceptance Requirements for Supplies and
          Consumables. . . . . . . . . . . . . . . . . . . . . .7
     B9.  Data Acquisition Requirements. . . . . . . . . . . . .8
     B10.  Data Management . . . . . . . . . . . . . . . . . . .8

C.  Assessment/Oversight . . . . . . . . . . . . . . . . . . . .8
     C1.  Assessments and Response Actions . . . . . . . . . . .8
     C2.  Reports to Management. . . . . . . . . . . . . . . . .8

D.  Data Validation and Usability. . . . . . . . . . . . . . . .8
     D1.  Data Review, Validation, and Verification Requirements9
     D2.  Validation and Verification Methods. . . . . . . . . .9
     D3.  Reconciliation with User Requirements. . . . . . . . .9

Appendix A
          Figure 1 - Project Organization
          Figure 2 - Overall Site Map
          Figure 3 - Site Map with Sampling Locations

Appendix B
          Analytical Services Request Form
          Sampling Supplies Request Form


(Note: The Appendices are not available in this HTML document. 
To view the document with the appendices, download the zipped
WordPerfect document.)



A. Project Management A3. Distribution List Contractors-R-Us: John Smith, Project Manager Joe Jones, Project Supervisor Susan James, QA Manager Mary Brown, Field Team Leader EPA - Region 7 Mark Johnson, Project Manager Jane Doe, Project Supervisor Mike Peterson, QA Manager Lisa Dixon, Lab Director A4. Project/Task Organization The individuals directly involved with the Rawhide project and their specific responsibilities are outlined below. See also, Appendix A, Figure 1. Mark Johnson, EPA Region 7 Project Manager: Overall coordination of the project and decision maker. Review and approve QAPP and subsequent revisions in terms of project scope and objectives. Ensure QAPP implementation. Mike Peterson, EPA Region 7 QA Manager: Review and approval of QAPP and subsequent revisions in terms of quality assurance aspects. Conduct assessments of field activities. Lisa Dixon, EPA Region 7 Lab Director: Coordination and scheduling of lab analysis, data review, and validation. John Smith, Contractors-R-Us Project Manager: Overall coordination of field work. Oversee preparation of QAPP. Implement final, approved version of QAPP. Susan James, Contractors-R-Us QA Manager: Review and approval of QAPP. Conduct in-house audits of field operations. Mary Brown, Contractors-R-Us Field Team Leader: Direct the sampling operations according to the QAPP. A5. Problem Definition/Background The Rawhide Superfund Site is a former leather tannery disposal area (the actual tannery was located elsewhere). Between 1982 and 1985, tannery waste sludge was landfarmed over part or all of a 29-acre pasture. "Landfarming" refers to a process of waste disposal that involves spraying or pouring waste onto the soil and then disking the waste into the soil. Sludge containing high levels of chromium compounds was disposed of at this site. Historical site information indicates that several portions of the landfarm area have received little or no waste. High concentrations of chromium III and VI have been detected in surface soil samples at the landfarm (based upon the results of a preliminary assessment performed in June 1988). This may indicate that wastes were dumped on the ground, but not disked into the soil. Groundwater sampling in wells and springs within three miles of the site have shown the presence of chromium and lead at levels below the maximum contaminant level (MCL) of 0.1 mg/L for chromium and the action level of 0.015 mg/L for lead. Due to the high levels of chromium in the surface soil, the site has been placed on the National Priorities List (NPL). The site is currently used to graze cattle. Several residences are located adjacent to the site (see Appendix A, Figure 2). Potential human exposure routes identified by the site risk assessor include ingestion and inhalation of soil particulates and ingestion of ground water. Chromium VI compounds are suspected human carcinogens through the inhalation pathway only. Chromium III compounds are not considered carcinogenic. Direct contact with chromium compounds can cause a hypersensitivity reaction. The potential land use for the site is residential and residents can be exposed to contaminants in soil and groundwater via ingestion. They can also be exposed to contaminated particulates via inhalation. Since the site is on the NPL, a remedial investigation will be performed to determine which areas of the soil pose an unacceptable risk to human health or the environment and require further response action. A6. Project/Task Description The purpose of this project is to determine if chromium-contaminated soil exists on-site and if it exceeds the health-based action level established for the site. The objectives for the project involve measuring the mean concentration of total chromium in surface soils on site for comparison to the health-based action level. The resulting data will be used to determine if the site poses a threat to potential residents and to recommend further response actions. If the mean total chromium concentration in the surface soil of an exposure unit (see section B1 for additional information on exposure units [EU]) exceeds 600 ppm, then further assessment or a response action will be recommended. A health-based non-carcinogenic action level of 600 PPM for total chromium has been established for this site because it is lower than the risk-based carcinogenic PRG of 700 PPM for hexavalent chromium and is considered more protective (these action levels were identified in consultation with ATSDR). The project is scheduled to begin Monday, October 28 and is expected to last four days. Sampling supplies are requested for pickup on October 25. (See appendix B for the completed ASR and SSR.) The activity number for this project is DSZR2 and samples will be delivered to the lab on Friday, November 1. Surface soil equipment will be used for sampling and ICAP will be used for analysis. A7. Quality Objectives and Criteria for Measurement Data The project data quality objective is to provide valid data of known and documented quality for the exposure units sampled to determine the mean total chromium concentration for comparison to the associated action level. The data quality indicators to be measured are identified below. The goals for analytical precision and accuracy are described in R7 ENSV SOP 3122.2C and will be applicable to this project. The acceptance limit for the precision assessed via field duplicate samples can be found in the R7 ENSV LAST QCSUM report. Representativeness will be addressed by collecting the samples as described in this document. Comparability will be addressed by collecting, analyzing, and reporting the data as described in this document. A completeness goal of 100% is needed for the project. Valid data is required for each EU in order to make a decision regarding the need for further action or no action for that EU. A9. Special Training Requirements/Certification No special training requirements or certifications are required for this project except for the 40-hour HAZWOPER class and annual refreshers. Information concerning the personnel qualifications for those individuals performing the work can be found in the Regional Laboratory Quality Manual and the Contractors-R-Us Quality Management Plan (approved by EPA on July 1, 1995). A10. Documentation and Records This information is covered by Region 7 ENSV SOPs 2410.1B, "LABO Analytical Data Management Procedures" and 2410.10A, "Analytical Data Submission Packages". B. Measurement/Data Acquisition B1. Sampling Process Design For this project, surface soil is defined as the top 0-2 inches of soil within the geographic boundaries of the 29-acre landfarm area, excluding forested areas where landfarming and disposal could not have taken place. The entire site has been divided into square areas that are approximately 200 x 200 feet. These areas are approximately one acre (one acre is actually 43, 560 ft2)in size and correspond to the expected residential lot size (see Appendix A, Figure 3). These areas are referred to as exposure units (EUs; R7 ENSV SOP 2230.1A, "Procedure for Collecting Soil Samples and Using the Resulting Data to Calculate Exposure Unit Statistics"). EUs which overlap the site boundaries will be combined with EUs having forested areas so that 20 EUs of approximately one acre will result. A separate decision will be made for each EU. The center of each EU will be marked with a wire flag and composite soil samples will be collected from each EU using a systematic grid. B2. Sampling Methods Requirements A systematic grid with nine nodes will be used to collect three composite samples from each EU. The samples will consist of nine aliquots collected from each of the nine nodes at a depth of 0-2 inches in accordance with R7 SOP 2231.12 "Soil Sampling" (the section addressing the collection of surface soil samples). Stainless steel spoons will be used to collect the soil aliquots which will be homogenized in aluminum pie pans. Dedicated stainless steel spoons and aluminum pie pans will be used for each exposure unit. The aluminum pie pans will be bagged and disposed of with the other PPE (i.e., gloves) as described in the site Health and Safety plan. The stainless steel spoons will be decontaminated after sample collection is complete in accordance with R7 ENSV SOP 2231.6A, "Sampling Equipment Decontamination." Duplicate samples will be collected as composites of nine aliquots that are offset from the original grid nodes at a frequency of 10% of all samples collected. With 20 EUs and three composites per EU, 60 soil samples and 6 duplicates will be collected for a total of 66 soil samples. Contractors-R-Us will conduct the sampling in accordance with this QAPP. B3. Sample Handling and Custody Requirements Sample containers, preservation, and holding times will be those found in R7 ENSV SOP 2130.4B, "Sample Container Selection, Preservation, and Holding Times." Chain-of-custody and field documentation will be in accordance with R7 ENSV SOP 2130.2A, "Field Chain of Custody for Environmental Samples" and R7 ENSV SOP 2130.3B "Identification, Documentation, and Tracking of Samples," respectively. The time of collection, location, sample section size, number of aliquots, and the sample depth will be recorded on field sheets produced by the EPA LAST system. B4. Analytical Methods Requirements The soil samples will be analyzed by the R7 Laboratory in accordance with R7 ENSV SOP 3122.2C, "Analysis of Metals by TLA ICAP 61". The typical detection limit for chromium following this SOP is 0.908 mg/kg which is adequate to meet the action level of 600 PPMThe overall implementation of the quality assurance program by the Regional laboratory is addressed in the R7 ENSV Sops 1640.1, "Region 7 Laboratory Quality Assurance Project Plan" and 1610.1C, "Regional Laboratory Quality Control Policy". B5. Quality Control Requirements Duplicate samples will be collected at a frequency of 10% of all soil samples collected. No split samples, field blanks, or trip blanks are planned for this project. Laboratory quality control elements, including spikes and blanks, will be performed in accordance with the above referenced analytical SOP and SOP 1610.1C. B6. Instrument/Equipment Testing, Inspection, and Maintenance Requirements The only field equipment being used during this project are stainless steel spoons and aluminum pie pans . No field equipment requiring testing, inspection, and maintenance will be used. For the analytical instrumentation, the testing, inspection, and maintenance will be performed in accordance with the above referenced analytical SOP and manufacturer's recommendations. B7. Instrument Calibration and Frequency No field instruments requiring calibration will be used for this project. For the analytical instrumentation, the calibration will performed in accordance with the above referenced analytical SOP and manufacturer's recommendations. B8. Inspection/Acceptance Requirements for Supplies and Consumables No special requirements are needed. B9. Data Acquisition Requirements No data will be used from other sources. B10. Data Management Data management will be in accordance with R7 ENSV Sops 2120.2A, "Document Control" and 2410.1B "LABO Analytical Data Management Procedures." C. Assessment/Oversight C1. Assessments and Response Actions The EPA QA manager (or his designee) will conduct an audit of the field activities for this project as requested by the EPA project manager according to R7 ENSV SOP 2152.2A, "Conducting On-Site Reviews of Field Sampling Activities." The EPA QA manager (or his designee) will have the authority to issue a stop work order upon finding a significant condition that would adversely affect the quality and usability of the data. The EPA project manager will have the responsibility for initiating and implementing response actions associated with findings identified during the on-site audit. Once the response actions have been implemented, the EPA QA manager (or his designee) will perform a follow-up audit to verify and document that the response actions were implemented effectively. In-house audits performed by the contractor may be conducted in accordance with the Contractors-R-Us Quality Management Plan (approved by EPA on July 1, 1995). Assessments and response concerning the analytical aspect of the project are addressed in the Sops 1610.1C, 1640.1A, and 3122.2C. The information covers examples of conditions indicating out-of-control situations, whom is responsible for initiating the corrective actions, and what steps may be taken. C2. Reports to Management Once the project is complete and the resulting data obtained, the EPA project manager will prepare a final project report. The report will include a summary of the activities performed during the project and the resulting data (along with any statements about problems concerning data quality). The EPA project manager will also identify any EU where the mean total chromium concentration exceeds the action level and recommend the need for further assessment or recommend a response action. The report will be forwarded to the EPA project supervisor. D. Data Validation and Usability D1. Data Review, Validation, and Verification Requirements The data will be peer reviewed by a qualified analyst and the lab Section Manager as identified in R7 ENSV Sops 1640.1A and 1610.1C. The EPA project manager will be responsible for overall validation and final approval of the data in accordance with project purpose and use of the data. D2. Validation and Verification Methods The data will be validated in accordance with R7 ENSV Sops 1610.1C and 1640.1A. QC spot checks will be performed by the R7 laboratory following the frequency and criteria outlined in R7 ENSV Sops 1640.1A and 1610.5A, "Quality Control Spot Checks of Regional Laboratory Data Packages." The EPA project manager will perform the final review and approval of the data prior to it being entered into the LAST system as valid. The EPA project manager will look at field duplicates, matrix spike/matrix spike duplicates, lab blanks, and lab duplicates to ensure they are acceptable. The EPA project manager will also compare the sample descriptions with the field sheets for consistency and will ensure that any anomalies in the data are appropriately documented. D3. Reconciliation with User Requirements Once the data results are compiled, the EPA project manager will review the field duplicates to determine if they fall within the acceptance limits as defined in this QAPP. Completeness will also be evaluated to determine if the completeness goal for this project has been met. If data quality indicators do not meet the project's requirements as outlined in this QAPP (including the accuracy for lab spikes), the data may be discarded and re-sampling may occur. The EPA project manager will evaluate the cause of the failure (if possible) and make the decision to discard the data and re-sample. If the failure is tied to the analysis, calibration and maintenance techniques will be reassessed as identified by the appropriate lab personnel. If the failure is associated with the sample collection and re-sampling is needed, the samplers will be retrained.

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