ARCHIVED REPORTS_WORK PLAN TO ESTABLISH BACKGROUND SOIL CONCENTRATIONS

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GESS • GENESIS ENGINEERING&REDEVELOPMENT selected and implemented. System audits typically consist of on-site reviews of both field and laboratory systems and facilities for sampling, calibration, and measurement protocols. The QA Manager or designated personnel may audit the laboratory regularly. In addition to the laboratory's internal auditing and auditing by Laboratory QC Manager, audits may be performed by the Project Manager, QA Manager, or applicable governmental and private agencies. These audits are performed to verify the following conditions: • Standards,procedures, records, charts, software, have been properly maintained • QC records have been adequately filed and maintained, and documents are protected and retrievable • Results of QC sample analyses have been assessed Formal audit reports will be distributed to the Project Manager and the Executive Management Team, if warranted. The results of the audit will be documented in a bound logbook, or permanently attached and maintained as part of the QA documentation. • 9.1.2 Field Audits The Field Team Leader may conduct internal field audits during field activities, in conjunction with field sampling events at the site. The objectives are to ensure that the Work Plan to Establish Background Concentrations is followed, that QC measures have been implemented and maintained,and that sample integrity has not been compromised. Upon completion of the field audit, a report and briefing documenting the findings will be provided to the Project Manager. Deficiencies encountered will be listed in the report and a corrective action will be initiated, as appropriate. 9.2 Corrective Action Procedures A corrective action will be initiated through the development and implementation of routine internal QA/AC checks, and the requirements for a corrective action will be implemented in response to deficiencies encountered during system audits or failure to adhere to the QAPP. To enhance the timeliness of corrective action and thereby reduce the generation of unacceptable measurement data,the problems identified by the assessment procedures will be resolved by the laboratory at the lowest possible management level. All problems requiring corrective action will be documented on a corrective action documentation form • William DePaoli Property 18 of 21 Quality Assurance Project Plan February 2012