Quality Assurance Project Plan Including Sampling And Analysis Plan (Page 48 of 67) in pdf

Hunters Point Shipyard Parcel F ESTCP Demonstration Plan

Appendix A: Quality Assurance Project Plan

The Project Manager will communicate with each analytical laboratory on a regular basis while the

project samples are being analyzed. This will allow assessment of progress in meeting DQOs and

Management Quality Objectives (MQOs), and the identification of any problems requiring corrective

actions early in the investigative process. The Project Manager will review any identified problems and

provide for the swift implementation of any outstanding corrective actions.

A.4.1.2

Response Actions

An effective QA program requires prompt and thorough correction of nonconformance conditions that

can affect quality. Rapid and effective corrective action minimizes the possibility of questionable data or

documentation.

Two types of corrective actions exist: immediate and long term. Immediate corrective actions include

correction of documentation deficiencies or errors, repair of inaccurate instrumentation, or correction of

inadequate procedures. Often, the source of the problem is obvious and can be corrected at the time it is

observed. Long-term corrective actions are designed to eliminate the sources of problems. Examples of

long-term corrective actions are correction of systematic errors in sampling or analysis and correction of

procedures producing questionable results. Corrections can be made through additional personnel train-

ing, instrument replacement, or procedural improvements. One or more corrections may be necessary.

QA problems and corrective actions will be documented to provide a complete record of QA activities

and to help identify needed long-term corrective actions. Defined responsibilities are required for

scheduling, implementing, documenting, and ensuring the effectiveness of the corrective action.

A.4.1.2.1

Field Corrective Actions

Field nonconformance conditions are defined as occurrences or measurements that are either unexpected

or that do not meet established acceptance criteria and which will affect data quality if corrective action is

not implemented. Some examples of nonconformance conditions include incorrect use of field equipment;

improper sample collection, preservation, storage, or shipment procedures; incomplete field docu-

mentation, including custody records; incorrect decontamination procedures; incorrect collection of QC

samples; and unsafe field practices.

Corrective action procedures will depend on the severity of the nonconformance condition. In cases in

which immediate and complete corrective action is implemented by field personnel, the corrective action

will be recorded in the field log notebook. Nonconformance conditions which have a substantial impact

on data quality require completion of a corrective action request form (however named). This form may

be filled out by an auditor or by an individual who suspects that any aspect of data integrity is being

affected by a field nonconformance issue. Each form is limited to a single nonconformance issue; if

additional problems are identified, multiple forms must be used for documentation.

Copies of the corrective action request form will be distributed, as appropriate, to the Project Manager,

the Project QA Manager, and the project file. The problem resolution will follow the steps listed below:

•

Determine when and how the problem developed;

•

Assign responsibility for problem investigation and documentation;

•

Determine corrective actions to eliminate the problem;

•

Design a schedule for completion of the corrective action;

•

Assign responsibility for implementing the corrective action; and,

•

Document and verify that the corrective action has eliminated the problem.

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Quality Assurance Project Plan Including Sampling And Analysis Plan Page 48

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