Uniform Federal Policy Quality Assurance Project Plan (UFP-QAPP) – A Consultant’s Overview

In 2005, the Director of the Federal Facilities Restoration and Reuse Office of the United States Environmental Protection Agency (EPA) issued a memo stating:

“The Uniform Federal Policy for Quality Assurance Project Plans (UFP-QAPP) has been approved by the Office of Solid Waste and Emergency Response (OSWER) and the Department of Defense (DoD) for use at federal facility hazardous waste sites. The purpose of this Memorandum  is to inform you that Quality Assurance  Project Plans prepared and approved according  to the UFP-QAPP meet all the requirements of EPA Requirements for Quality Assurance Project Plans, (QA/R-5) issued by the Quality Staff of the Office of Environmental  Information.

…the UFP-QAPP elected to take on topics that had not been addressed  in the past, beginning with the adequacy of sampling plan design, through field sampling activities, to data review, with an emphasis  on the quality of data, related to the decision that requires environmental data.” The EPA memo in its entirety can be read here. http://www2.epa.gov/sites/production/files/documents/oswer_9272.0_20.pdf

In April 2006, the Office of the Under Secretary of Defense released a memorandum stating:

“In March 2005, Thomas Dunne, Acting Administrator for the U.S. EPA Office of Solid Waste and Emergency Response (OSWER) joined me in signing the Uniform Federal Policy for Quality Assurance Project Plans(UFP-QAPP),  thereby formally adopting the policy for use at Federal facility hazardous waste sites. Recently, EPA issued a directive and guidance for EPA Regions to require use of the UFP-QAPP for collection of data at Federal facility hazardous waste sites involving CERCLA, RCRA, and Brownfields type projects. The purpose of this memorandum is to request that Components begin immediate implementation of the policy.” The full DoD memo can be read here: http://www.denix.osd.mil/edqw/upload/ADUSD_MEMO.PDF

UFP-QAPP stands for Uniform Federal Policy – Quality Assurance Project Plan. It is the result of extensive collaborations between the EPA, the DoD, and the Department of Energy (DOE). The original 37 work-sheet version of the UFP-QAPP was released by the EPA in 2005. By 2009, most DoD components had adopted the UFP-QAPP for environmental work. Although the DOE was instrumental in developing the UFP-QAPP, it has not to-date formally adopted the policy; however, its use may be required on DOE projects under specific programs.

The updated, optimized 28 worksheet version released by the EPA in 2012 combines several worksheets to reduce redundancy. The prompts were also updated to be more helpful and relevant to industry than those found in the original version. The optimized format with prompts can be found here: http://www2.epa.gov/sites/production/files/documents/ufp_qapp_worksheets.pdf

The UFP-QAPP is much more than a traditional Quality Assurance Project Plan (QAPP) and if the current optimized template is followed with care, all aspects of project planning except Health & Safety will be considered. The document was intended to be a Sampling and Analysis Plan (SAP) inclusive of a Field Sampling Plan (FSP) and QAPP. It was also intended to be a collaborative document written by project managers, hydrogeologists, chemists, and engineers working together, although it is wise to have a lead author to ensure a coherent and cohesive whole, as is the case with any other project document. In its current form, the UFP-QAPP has the potential to fulfill all Work Plan (WP) requirements except Health & Safety.

Although some Worksheets focus on laboratory actions, data validation, and chemical quality control (QC), this is a small part of the UFP-QAPP. The text below provides a summary of Worksheets for which information must be provided by Project Management and/or technical leads:

QAPP Worksheet #1 and 2: Title and Approval Page

This page requires identification of the contract number, the lead organization’s Project and Quality Managers, the relevant regulatory agencies and other stakeholders, as well as a list of previous reports related to the project. Once the document is complete and finalized, this worksheet is where client and contractor Project and Quality Managers sign off to indicate approval of the final plan.

QAPP Worksheet #3 and 5: Project Organization and QAPP Distribution

This page may simply be an organizational chart. It requires inclusion of specific individuals within the lead agency as well as contractor and subcontractor personnel.

QAPP Worksheet #4, 7 and 8: Personnel Qualifications and Sign-Off Sheet

Names, project roles, education, and certifications are to be listed here. Once the UFP-QAPP is complete, primary personnel should also sign here to indicate that they agree to follow the plan.

QAPP Worksheet #6: Communication Pathways

The prompt for the optimized version of this worksheet states: “This worksheet should be used to document specific issues (communication drivers) that will trigger the need to communicate with other project personnel or stakeholders. Its purpose is to ensure there are procedures in place for providing the appropriate notifications and generating the appropriate documentation when handling important communications, including those involving regulatory interfaces, unexpected events, emergencies, non-conformances, and stop-work orders.” As a general rule, this is a good place to document who is responsible for day-to-day communications as well and with whom and how (email, phone, in person) those communications are to occur.

QAPP Worksheet #9: Project Planning Session Summary

Project kick-off meetings and any other scoping sessions should be documented in Worksheet #9. Ideally, the technical lead(s) and/or contractor Project Manager ensures all of the necessary information is recorded and supplied to the lead author. Although the EPA does not recommend simply taking Worksheet #9 to the scoping sessions, it can be useful as a guidance for what information is needed. In the context of the UFP-QAPP, “scoping session” means any meeting during which the project scope is discussed and alignment is ensured even if there are no modifications to the formal Scope of Work.

The EPA offers workshops for UFP-QAPP preparation and numerous on-line documents to assist in preparation of a UFP-QAPP. One of these is the Participant’s Guide for How to Plan Projects Using the Uniform Federal Policy for Quality Assurance Project Plans, Training Workshop which can be accessed here: http://www2.epa.gov/sites/production/files/documents/participant_guide_ufp_qapp_workshop_v_01.pdf

This document provides examples for planning for projects using the UFP-QAPP including preparing for and conducting scoping meetings (as defined by the UFP-QAPP) with your client.

QAPP Worksheet #10: Conceptual Site Model

The title of this Worksheet is self-explanatory. This is where you develop and/or present your Conceptual Site Model (CSM). The optimized UFP-QAPP template provides prompts for discussing site history; sources of known or suspected hazardous waste; known or suspected contaminants or classes of contaminants; primary release mechanism(s); secondary contaminant migration; fate and transport; potential receptors and exposure pathways; land use considerations; key physical aspects of the site (site geology, hydrology, topography, climate) as pertinent to the project; the current interpretation of the nature and extent of contamination; and any data gaps and uncertainties associated with the CSM. Depending on the nature of your project, the input of your hydrogeologist, geochemist, chemist and/or engineer can be useful for completing this worksheet.

QAPP Worksheet #11: Project/Data Quality Objectives

This worksheet walks the author through a systematic planning process (SPP). The template specifically walks through the EPA’s 7-step Data Quality Objective (DQO) process. For Step 4, it’s important to define temporal (schedule) as well as spatial boundaries. For spatial boundaries, for example, it’s simple to say your team will dig and haul until PALs are met. However, this is risky without indicating at what depth you’ll make another call, or determining what you’ll do if you hit bedrock or groundwater.

Make sure to include reasonable “if/then” statements in Step 5 as well.

If you are unfamiliar with the EPA’s 7-step DQO process, you can find an introduction to this SPP here: http://www2.epa.gov/quality/training-courses-quality-assurance-and-quality-control-activities#intro_dqos

QAPP Worksheet #14/16: Project Tasks & Schedule

The title of this worksheet is self-explanatory. This is where your schedule or task list should be developed or added to the plan.

QAPP Worksheet #17: Sampling Design and Rationale

This is a good place for figures showing proposed and/or known sampling locations. The prompts provide some guidance on developing a sampling plan, and your technical leads in all fields could have valuable insight to be included here.

Other Worksheets

Other worksheets in the plan may appear to be similar to a traditional QAPP and may seem “chemistry focused” from a non-chemist point of view; however, dismissing these worksheets as “fill in the blank” sections is a mistake that can impact your budget, plan, and schedule.

You need to determine or identify what regulatory or project-specific PALs you will use in Worksheet #15, and you will need to address what your decision process and criteria will be if current methodology is unable to achieve these PALs. Levels of validation and QC sample requirements will also need to be identified. The input of an experienced environmental chemist is advised. Copying and pasting from old plans without careful consideration of actual project objectives could lead to unnecessary expenditure of budget and schedule, as you will be bound to following the plan. It’s important not to treat the details as administrative.

The topics addressed in the UFP-QAPP worksheets can help you and your team plan for efficient, effective project execution and assist you in meeting regulatory requirements for project planning. The EPA Frequently Asked Question (FAQ) page provides a tidy overview for understanding the UFP-QAPP: http://www2.epa.gov/sites/production/files/2014-02/documents/ufp_qapp_faq.pdf

It is important to understand the expectations and requirements of your client. While these requirements may seem to be clearly spelled out in your Request for Proposal (RFP), communication is vital. You don’t want to expend budget and schedule on multiple planning documents if your client would be satisfied with a UFP-QAPP and Health & Safety Plan (HASP).

If a UFP-QAPP is required but your team prefers other documentation in the field, it may be time to adjust to a new approach, and this can often be achieved by engaging the team in preparation of the UFP-QAPP for your DoD project. Once the team is comfortable that the contents of the UFP-QAPP are usable and meet their needs, they can identify the individual worksheets needed for their specific tasks and refer to those worksheets alone, as needed.

Some DoD clients require preparation of a UFP-QAPP for any type of environmental sampling, including sampling conducted only in conjunction with demolition for the purpose of confirming demolition has not caused new contamination. However, if there is an installation-wide QAPP in place for your project, or there is an approved and applicable QAPP in place for an on-going project undergoing re-assignment, the UFP-QAPP requirement may be waived or reduced. Even so, you may want to consider preparing a new UFP-QAPP to confirm that your understanding of the project is in alignment with current client expectations. Legacy documents do not always capture changes that can occur over time on long-term monitoring or maintenance projects. Any request to reduce or eliminate a UFP-QAPP requirement should be in the client’s best-interest.

In the author’s experience, use of the UFP-QAPP as an over-arching WP is client–dependent, and sometimes district-dependent. Some DoD clients want a complete UFP-QAPP, plus an FSP and a separate WP, and possibly a variety of additional plans. Some clients prefer only a UFP-QAPP and a HASP. The Naval Facilities Engineering Command (NAVFAC) may expect you to use a NAVFAC specific version called the UFP-SAP. The UFP-SAP is based on the original UFP-QAPP with minor modifications. Regardless of what your client needs or requires, the prompts in the optimized UFP-QAPP template provide useful guidance for planning.

One concern that has been expressed is that failure to address details is generally not acceptable in a UFP-QAPP. However, most clients are aware that project execution can be unpredictable. It is possible to write the UFP-QAPP so that there is room to make real-time field decisions or use alternate approaches. In fact, the UFP-QAPP can better prepare your team to make these decisions. It is also not necessary to repeat relevant information provided elsewhere in the UFP-QAPP.

Example:

“Samples will be collected from the approximate former location of the pipeline. Samples will also be collected from the approximate bottom of the disposal pit and/or immediately downgradient of the pit, depending upon site conditions. Approximate locations and depths of the pipeline and pit were identified through use of the historical documents provided in Appendix A. GPS will be used to record exact sampling locations in the field. See Worksheet 18.

If necessary, additional delineation sampling will be performed as step-outs and/or step-downs until analytical results are below the project action levels (PALs) shown on Worksheet 15-1 or no impact to groundwater is identified using downgradient groundwater data with results less than the PALs shown in Worksheet 15-2. See Worksheet 11 for details on boundaries to project decisions and specific if/then questions. See Worksheet 20 for anticipated sample quantities and associated QC.”

Although not intended to be all-encompassing, the above example shows how your team might meet UFP-QAPP requirements, prepare for real-time field decisions, and ensure your engineers, hydrogeologists, chemists, and project manager(s) are aligned.

Clients are seeking a clear, well thought-out plan for project execution, and preparing the UFP-QAPP can help ensure this expectation is met. Initially, the document may seem onerous, but its guidance provides for a thoughtful approach to planning that can better prepare your team for efficient, effective project execution. Careful planning and team alignment saves time and reduces difficulties during project execution. And because efficient, effective project execution is the best path to ethical, profitable project completion, a UFP-QAPP can be an invaluable project planning tool.

If you have questions or comments, please leave them in the comments section below. If you’d like to find out if Oak Services is the right company to prepare or review your UFP-QAPP or other planning documents, please contact us and let us know what you’re looking for.

References

2013, DoD, DoD Quality System Manual Version 5.0, July.

2006, DoD, Memorandum for Deputy Assistant Secretary of the Army (environmental, Safety, and Occupation Health), Deputy Assistant of the Navy (Environment), Deputy Assistant of the Air Force (Environment Safety and Occupational Health), Director Defense Logistics Agency (DSS-E), April.

2014, EPA, Frequently Asked Questions: Uniform Federal Policy for Quality Assurance Project Plans, February.

2012, EPA, Intergovernmental Data Quality Task Force Uniform Federal Policy for Quality Assurance Project Plans, Optimized UFP-QAPP Worksheets, March.

2011,EPA, Participant’s Guide for How to Plan Projects Using the Uniform Federal Policy for Quality Assurance Project Plans (UFP QAPP), Training Workshop Guide, October.

2005, EPA, Memorandum, OSWER GUIDANCE 9272.0-20, Applicability of the Uniform Federal Policy for Quality Assurance Project Plans (EPA 505-04-900A), December.

2005, EPA, Office of Solid Waste and Emergency Response, OWSER Directive 9272.0-17 Implementation of the Uniform Federal Policy for Quality Assurance Project Plans (UFP-QAPP) and Federal Facility Hazardous Waste Sites, June.

2005, EPA, Intergovernmental Data Quality Task Force Uniform Federal Policy for Quality Assurance Project Plans, Evaluating, Assessing, and Documenting Environmental Data Collection and Use Programs, March.

 

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