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The QAPP should define the data quality objectives on a project- <br /> specific basis and explain how these objectives will be achieved. <br /> The QAPP takes precedence over the laboratory QA/QC program and <br /> it should clarify the QC requirements for each specific method, <br /> since the methods are sometimes not clear or are open ended in <br /> defining analytes and QC requirements. DDRW-Tracy should revise <br /> this QAPP to define a QA/QC program the meets the needs of this <br /> project, not adopt the QC program of a yet unspecified <br /> laboratory. It is highly recommended that this program, once <br /> defined, be reviewed with the laboratory to ensure that it is <br /> either consistent with their standard practices or to ensure that <br /> he project's requirements can be met. <br /> Specific comments follow, but the entire QAPP should be revised <br /> and the following comments only reflect major areas of concern. <br /> 1. Title page: <br /> Because this is not an EPA lead site, the EPA QA officer <br /> does not have to approve the plan. The names of the <br /> responsible individuals should be added tot he signature <br /> blocks. It is not clear who"Funding Organization" is meant <br /> to represent. DDRW-Tracy, or an appropriate specific <br /> organization should replace this designation. <br /> 2 . Section B.3. 1: <br /> This section talks about current sampling activities along <br /> with past sampling activities. Confusion results as to <br /> which chemical will be evaluated in the current sampling <br /> effort. Revise/clarify the text. <br /> 3 . Section B.3.2, Objectives: <br /> Data Quality Objectives for the' site need to be analyte <br /> specific, based on the end use of the different areas of the <br /> site, or alternatively, on applicable and relevant <br /> regulations (ARARs) . Stating that objectives will be used <br /> both for characterization purposes and to do risk assessment <br /> suggests that the project goals are unclear, or need to be <br /> defined on a site by site basis within DDRW-Tracy. An <br /> effort should be made to establish DQOs that reflect risk- <br /> based or health-based criteria. It is acceptable, but less <br /> desirable, to establish DQOs based on the capabilities of <br /> the methods. Whether DQOs or measurement quality objectives <br /> (MQOs) are used, they should be examined to determine <br /> whether they are sufficient to provide the quality of the <br /> data necessary to make decisions concerning DDRW-Tracy' s <br /> future use. Numerical objectives for precision, accuracy, <br /> completeness, and quantitation limits should be provided. <br /> IV-2 <br />