More About Quality Assurance (QA) Program Plan
What is a Quality Assurance (QA) Program Plan?
A QA Program Plan describes the quality process that is used by a particular program; in this case, the Nevada Brownfields Program (NBP). The QA Program Plan describes the program's organization, quality objectives, quality control processes, and assessment and oversight functions. The U.S. Environmental Protection Agency (EPA) Region 9 Requirements for QA Program Plans, R9QA/03.1 (2001) states that: "All organizations conducting environmental programs funded by EPA are required to establish and implement a quality system." A QA Program Plan is part of that Quality System.
Why does the Nevada Brownfields Program need a QA Program Plan?
Programs and projects receiving funding from EPA as extramural agreements are subject to EPA quality requirements. Authorizing regulations for these requirements include 40 CFR Part 31 "Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments" and Part 35, "State and Local Assistance."
EPA requires that agreements with states document the organization's Quality System, as well as program and project-specific QA and quality control (QC) activities. Environmental projects that are funded directly from EPA Region 9 are required to have a QA Program Plan. The QA Program Plan describes what type of activities or projects require a QA Project Plan or other QA documentation, and which are covered directly under the QA Program Plan. The QA Program Plan also describes what information the project plans should include or provides appropriate references, such as EPA's R-5 QA Project Plan guidance.
What is the Benefit of Having an Approved Brownfields QA Program Plan?
An EPA-approved QA Program Plan provides the NBP Quality Control Coordinator the authority to review and approve project plans. This allows a quicker turnaround of sampling and analysis plans (SAPs) submitted for Brownfields projects and helps keep project schedules on track. The NBP QC Coordinator will review submitted field sampling plans (FSPs) and SAPs to evaluate whether the sampling event will satisfy project goals, and if it includes sufficient QC elements to assure appropriate data quality.
Who Would Use the Brownfields QA Program Plan?
Consultants working on NBP projects must read and understand the specific sampling and analytical requirements outlined in the NBP QA Program Plan. In turn, this plan may be referenced in the case of routine sampling and routine analyses, allowing consultants to prepare a more succinct FSP or SAP for many NBP projects. Projects with standard media and analyses would require only an FSP and a citation of the QA Program Plan. Projects with unusual media or analyses would require a project-specific SAP, with a description of the QA/QC specifics for the non-standard media and analyses.
What Project-Specific Plans are Required for Nevada Brownfields Projects?
Any project that involves environmental sampling needs to have an approved FSP or SAP. The SAP template provided by EPA Region 9 may be used as a basis for NBP project-specific plans. This template is modified to suit a particular project; for example, projects without any type of biological sampling need not include Sections 6.6, Biological Sampling, or Section 7.4, Biological Samples. The idea is to tailor the basic template to best fit your project.