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ATTACHMENT IV <br /> EPA COMMENTS ON THE DRAFT COMPREHENSIVE <br /> SAP AND QAPP (APPENDICES A AND B) <br /> WORK PLAN (JAN-92) FOR DDRW-TRACY <br /> FIELD SAMPLING PLAN <br /> DDRW-Tracy should identify the potential chemicals of concern in <br /> the FSP, along with method detection limits. The specific <br /> analytes should be listed along with each method. <br /> The manufacturer's calibration procedures for the sounder, Ph <br /> meter, and the specific conductivity meter (Table A. 3 . 2) should <br /> be summarized in this Appendix. <br /> On page A-12 , Section A. 3 . 3 .2 . 1, no mention is made of purging <br /> the water supply wells prior to sampling and analysis. The FSP <br /> should explain how this purging is to be performed. (See also <br /> General Comment No. 7, in Attachment I) . <br /> QUALITY ASSURANCE PROJECT PLAN <br /> This Quality Assurance Project Plan (QAPP) , dated 2/6/92 (30 days <br /> after the initial due date stipulated in the FFA schedule for <br /> DDRW-Tracy) , was reviewed in terms of the guidance provided in <br /> "US EPA Region 9 Guidance for Preparing Quality Assurance Project <br /> Plans for Superfund Remedial Projects" (9QA-03-89, September, <br /> 1989) . <br /> First, information concerning specific analytes, specific quality <br /> control criteria, calibration, and laboratory procedures are not <br /> defined, but instead are referenced to the QA plan of a yet <br /> unselected analytical laboratory. Second, one major purpose of a <br /> QAPP is supposed to tell the laboratory what QA/QC <br /> procedures/protocols to follow (not the reverse) . <br /> Because the laboratory had not been selected at the time the QAPP <br /> was prepared, and because the QAPP does not independently define <br /> the QA program for DDRW-Tracy, the projects 's QA and QC program <br /> could not be reviewed fully. The QAPP must be completed before <br /> the QAPP can be recommended for approval. It is suggested that <br /> the above guidance be consulted before the QAPP is revised. It <br /> is also suggested that the laboratory be selected before the QAPP <br /> is resubmitted and, if DDRW-Tracy plans to adopt the laboratory' s <br /> practices, then include the appropriate laboratory documentation. <br /> IV-1 <br />