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November 13, 29D9taFUM0 0 U ^ W^\!/?% Project No. 09-142

Ms. Katrina Higgins-Coltrain ^ ' U.S. Environmental Protection Agency (EPA), Region VI Superfund Division (6SF-RL) 1445 Ross Avenue, Suite 1200 Dallas, TX 75202-2733

Notice Respondents' Proposed Proiect Coordinator and Contractor

Brine Service Companv Superfund Site Corpus Christi. Texas

Dear Ms. Higgins-Coltrain:

The purpose ofthis letter is to provide notice to EPA of:

1. Respondents' proposed Project Coordinator, pursuant to Section VIII, Paragraph 30 ofthe Brine Service Company Superfund Site Administrative Order on Consent, CERCLA Docket No. 06-09-04 (AOC); and

2. Respondents' proposed Contractor, pursuant to Section VIII, Paragraph 29 ofthe AOC.

The Respondents propose Mr. Roberto Puga, P.G. as the Project Coordinator. Mr. Puga has demonstrated the technical expertise sufficient to oversee the implementation ofthe AOC Statement of Work (SOW). A resume for Mr. Puga is included as Attachment 1.

The Project Coordinator's contact information is listed below:

Roberto Puga, P.G. Project Navigator, Ltd. One Pointe Drive, Suite 320 Brea, Califomia 92821 T:(714) 388-1802 F: (714) 388-1830 S S ' C: (714) 863-0484 oOMau E: [email protected]

The Respondents have selected URS Corporation as their Contractor. The Contractor's main point of contact and project team leader is Mr. Johnny Kennedy, P.G. URS Corporation has demonstrated the technical expertise necessary to perform the Work mandated under the AOC SOW.

ONE POINTE DRIVE, SUITE 320, BREA, CA 92821 T: (714) 388-1800 F: (714) 388-1839 www.projectnavigator.com

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mailto:[email protected]


http://www.projectnavigator.com

http://www.projectnavigator.com

Ms. Katrina Higgins-Coltrain November 13, 2009

Mr. Kennedy's contact information is listed below:

Johnny W. Kennedy, P.G. Senior Geologist URS Corporation - Houston Office 10550 Richmond Ave, Suite 155 Houston, Texas 77042 T: (713) 914-6549 F: (713) 789-8404 C: (281) 226-0862 E: [email protected]

Resumes for key URS personnel and a list of analytical laboratories to be used on this project are included in Attachment 2. Additionally, as required by AOC Section VIII, Paragraph 29, please find URS Corporation's Quality Management Plan in Attachment 3.

Lastly, as required by AOC Section XXV, Paragraph 95, please find an insurance certificate for the required coverages and including the U.S. EPA as additional insured in Attachment 4.

Please call or e-mail me with any questions.

Very Tmly Yours,

• p v ^ —

Roberto Puga, P.G.' Respondents Project Coordinator Designee

Attachments (4)

cc: Mr. Joseph Compton, EPA ORC Ms. Luda Voskov, TCEQ Brine Group Members URS Corporation

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Attachment 1

Resume for Mr. Roberto Puga, P.G.

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Roberto Puga, P.G.

Roberto Puga, P.G. Principal, Senior Project Manager

B.S. Geophysics University of California, Santa Barbara, 1988

Skills Multi-party group management, and facilitation towards decision-making

Regulatory agreement negotiations, especiaUy on scopes of work for UAO and CDs

Compliance management (Consent Decree, AOC, Health & Safety practices)

Geological and hydrological assessments, especiaUy in landfill gas/leachate migration analysis

Data mining and re-use via such techniques as GIS

Project scheduling, logistics and critical path analysis

Visual representation of complex technical concepts and scenarios

Preparation of effective and audience accessible technical reports and presentations

Project advocacy to agencies and public

Resource selection, team building and management

Contracting strategies

Regulatory agency costs review and negotiation

Representative Experience Malone Superfund Site, Texas City, Texas Project Coordinator for a multi-party PRP group. Acting as lead technical negotiator, managing Rl contractor and assists on group allocation issues. Successfully completed RI/FS process in 2008. Technical reviewer of ecological risk assessment process (SLERA/BERA). Lead NRD settlement technical negotiation.

Focused Experience

• Oil field disposal facility remedial investigation, feasibility study, design and remedial action technical management. Example projects include: Malone Superfund Site (Region 6), PAB Oil Superfund Site (Region 6), WDI Superfund Site (Region 9), Purity Oil Superfund Site (Region 9)

• Landfill site remediation strategy development and planning

• Smelting facility remedial design and action implementation

• Technical review of ecological risk assessments for sediment sites

< Regulatory negotiations

• Risk management

• Cost avoidance strategies

• Advocacy presentations

• Meeting facilitation

• Resource procurement

• Contracting Strategy

• Design and construction oversight

• Geological and hydrogeological assessments

PAB Oil Superfund Site, Abbeville, Louisiana Project Manager for Remedial Design and Remedial Action for this oil field waste disposal facility in EPA Region 6.

BKK Landfill, West Covina, California Project Coordinator and project manager for multi-party PRP Group. Acts as lead technical agency negotiator, and oversees the 30-person OM&M team at the approximately 200 acre landfill.

Tex Tin Superfund Site, Texas City, Texas Project Coordinator for multi-party PRP group. The Project Manager for the RD/RA. Oversaw the approval and procurement of a design-build contractor. Accomplished project completion below budget and ahead of schedule. Worked to maximize post-remediation site utility

WDI Superfund Site, Santa Fe Springs, California Project Coordinator for a multi-party PRP group. Acted as lead technical agency negotiator, and managed the RI/RD/RA efforts on the $21M project. This project included soil gas assessment migration and performance standard compliance issues.

Oil Superfund Site, Monterey Park, California Field Activities Manager for CD-3 RD investigations. Work included design and installation of gas wells, reconfiguration of leachate feed stock analysis, fault identification for seismic stability evaluations, geophysical measurements, complete revision of OMftM Manual

Purity Oil Superfund Site, Malaga, California Field Activities Manager during Rl/RD activities at this oil field waste facility. Planned and oversaw CPT program to delineate extent of TCE plume.

Employment History 1998 to Present Project Navigator, Ltd., Principal and Senior Project Manager;

Joined Ian Webster as a partner in PNL, and together have built an industry respected firm that has excelled in meeting clients' needs.

1988 to 1998 TRC Companies, Geologist, Senior Project Manager Began as a field geologist conducting investigations, steadily earning increasing responsibility. Ended tenure at TRC as a Senior Project Manager overseeing multi-million dollar Superfund projects.

Other California Professional Geologist No. 6346

Puga, R., Mason, J., Pearlson, J., Houldin, S., Making environmentally challenged deals work: Tools to manage risk and unlock value in contaminated real estate assets. Journal of Corporate Real Estate, Volume 5, Number 3, July 2003.

w y*^^ NAVIGAT i R, LTD.® Managing Strategies into Tactical Aciion

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Attachment 2

Resumes for Mr. Johnny Kennedy, P.G. and Dr. Brenda Basile, Ph.D.

and

List of Analytical Laboratories

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Johnny W. Kennedy, P.G. Senior Geologist/Project /Manager

Areas of Expertise • T C E Q Regulations

• Remediation and Site Assessment

Strategies

• Superfund Sites

• Pipeline Spill Closures through

T C E Q Regional and Central

Offices

• Emergency Response Incidents

• PST Program

Years of Experience With URS: 8 Years

With Other Firms: 9 Years

Education MS Geology/1999/University of Houston

BS Geology/1985/University of Texas at Austin

Reg istration/ Certification 2003/Licensed Professional Geologis/Texas/#l 024

Overview Mr. Kennedy is a Professional Geologist with more than seventeen years of

regulatory and consulting experience managing and performing multimedia

site assessments and implementation of remedial actions at contaminated

sites including large petroleum terminal facilities and refineries, specialty

chemical manufacturing facilities, pipelines and pump stations, railroad

intermodal and fueling facilities, and federal government facilities, and State

and Federal Superfund sites along the Gulf Coast. His career includes nine

years with the Texas Natural Resource Conservation Commission (now the

Texas Commission on Environmental Quality) as the Team Geologist and

Project Manager in the Preliminary Assessments/Site Screening Inspection

Program for the USEPA and the State Superfimd Program.

Project Specific Experience - URS • Lubrizol Coqjoration, Deer Park, Texas — Project Manager and

technical support for the development and implementation of strategic site-wide environmental initiative under die Texas Commission on Environmental Quality's (TCEQ) Texas Risk Reduction Program (TRRP). Project involves evaluation of aU available hydrogeologic data, constmction of site-wide hydrogeologic MODFLOW model, evaluation and implementation of innovative ground water remedial strategies, renewal of the facility's Compliance Plan and Resource Conservation Recovery Act (RCRA) Permit, various engineering' constmction programs, and preparation of long-term monitoring plans.

• B NSF Railway Company, Hous ton , Texas and Silsbee, Texas — Project Manager for multi-phase site investigations at the railroad intermodal facility in Houston, Texas and fueling facility in Silsbee, Texas. Projects included work plan preparation, review of historical records, identification of contaminant sources and delineation of surface and subsurface soil and ground water contamination, aquifer testing and evaluation, and submittal of summary reports to the client. Clostire documentation included completion of Affected Property Assessment Reports (APARs) and Response Action Completion Reports (RACRs) under the TCEQ TRRP.

• Former Coastal States Crude Gathering Company (El Paso Cotpotat ion) , Corpus Christi, Texas — Project Manager for multimedia site investigation of cmde oil and refined storage facility under jurisdiction of the Texas Railroad Commission (RRC). Manage separate source investigations as part of a facility-wide assessment. Evaluation remedial strategies and implementation of phase-separated hydrocarbon recovery. Provide cKent innovative

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risk-based approach for addressing environmental conditions. Maintain and update client project financials and business tools.

Former Coastal States Crude Gathering Company (El Paso Corporation) South Texas Crude Pipeline, La Salle County, Texas - Project Manager for a portfolio of projects along a former crude oil pipeliae and former crude oil storage and pumping stations. Projects involve soil and ground water investigations, remedial response actions, risk-based evaluations and documentation under the RRC. Maintain and update client project financials and business tools.

James Barr T C E Q State Superfund Site — Pearland, Texas — Project Geologist responsible for the installation of soil borings and monitoring wells to delineate soil and ground water chemicals of concern. Project deliverables included Field Sampling Plans, Protective Concentration Level (PCL) Report, Tier 2 PCL Report, Phase I and Phase II Remedial Investigation Technical Memoranda.

Malone Service Company, Federal Superfund Site - Texas City, Texas City, Texas — Project Geologist for the Remedial Investigation phase at the Site. Assisted in preparation of the Preliminary Site Characterization Report (PSCR), Preliminary Remedial Alternatives Evaluation Report (PRAER) and Remedial Investigation/Feasibility Study Work Plan (RI/FS Work Plan). Provide oversight for die collection of soil, sediment and ground water samples. Assisted in preparation of the Remedial Investigation Report regarding the Site geology, hydrogeology and the nature and extent of contamination at the Site.

Brio Superfund Site, Federal Superfund Site - Project manager for the plugging and abandonment of the former public water supply water well and the installation of recovery wells.

Baker H u g h e s Industrial Complex - Hous ton , Texas - Project Manager responsible for managing Phase I and Phase II Environmental Site Assessments at an active industrial complex.

BP Chemical Plant, Texas City - Project geologist responsible for project planning, preparation of site-specific health and safety plans, implementation of field sampling activities, and preparation of site closure documentation for three conctirrent investigations at the chemical plant under the TCEQ TRRP. Closure documentation included completion of APARs and RACRs submitted to the TCEQ.

T E Products Pipeline Company ( T E P P C O ) Pipeline Terminal Facility, Baytown, Texas - Project Geologist responsible for project planning, preparation of site-specific Health and Safety Plan, coordination and oversight of field sampling, and preparation of clostire documentation for a diesel fuel release to the ground surface. Calculated site-specific TRRP Tier 1 Protective Concentrations Levels (PCLs) using TPH TXI 006 analytical data and delineated impacted soil using TPH TXI 005 analytical data.

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Site closure granted from the TCEQ Region 12 Emergency Response Program through documentation that contaminant concentrations from the release product are protective of human health and the environment.

• T E P P C O Pipeline P u m p Stations, Chambers and N e w t o n County, Texas — Project Geologist responsible for project planning, preparation of site specific Health and Safety Plan, and coordination of field sampling at a refined product releases at pipeline pump stations. Site closures granted through TCEQ Regional Emergency Response Program.

• Kinder Morgan Liquids Terminals, LP, Galena Park, Texas -Project Geologist responsible for developing innovative strategies to address soU, air and ground water issues at three separate plant sites concurrentiy and the preparation of TCEQ Response Action Plans (RAPs). TCEQ approval of the RAPS without comment allowed for the implementation of three separate Plume Management Zones (PMZs) with significant cost savings for the client.

• Kinder Morgan Liquids Terminals , LP, Pasadena, Texas -Project Geologist responsible for project planning, preparation of site specific health and safety plans, field sampling and coordination of other field activities, and preparation of site closure documentation under the TCEQ TRRP. Closure documentation included completion of APARs and RACRs. Projects included assessments of subsurface soil and site remediation using In-Situ Chemical Oxidation (ISCO) for several sites at one of the largest petroleum storage tank terminals along the Houston Ship Channel. Closure of recent spills through both TCEQ Region 12 Emergency Response Program and TCEQ Corrective Action Section (CAS).

• Nat ional Aeronautics & Space Administration (NASA), Hous ton , Texas - Project Geologist for RCRA permit close-out activities. Prepared Field Sampling Plan, Sampling Analysis Plan, Health and Safety Plan for submission and approval to AFCEE. Oversight of field sampling and report preparation for submittal to TCEQ. Site closures granted to client under both the Texas Risk Reducrion Rules (RRR) and TRRP.

• BP Texas City Refinery, Texas City, Texas - Project Geologist responsible for project planning, preparation of site-specific health and safety plans, implementation of field sampling activities, and preparation of site closure documentarion for multiple sites at the refinery under the TCEQ TRRP. Closure documentation included completion of APARs and RACRs. Site clostire granted to client by the TCEQ CAS.

Project Specific Experience - TNRCC • Project Manager and Team Geologist under the USEPA Preliminary

Assessment/Site Screening Inspection (PA/SI) Program for the

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implementation of site assessment strategies and preparation of documentation for listing of Federal Superfund Site including:

o Malone Service Company Superfund Site, Texas City, Texas

o Gulfco Marine Maintenance Superfund Site, Freeport, Texas

o Many Diversified Interest Superfund Site, Houston, Texas

• Project Manager and Team Geologist for development and implementation of site assessment and remedial strategies at contaminated site including State Superfund Sites:

o Force Road Oil Company Site, Manvel, Texas

o James Barr Site, Pearland, Texas

Professional Societies/Affiliates Houston Geological Society

National Ground Water Association

Specialized Training National Ground Water Association, Assessment of LNAPL Volume, Mobility, and Recovery for Recovered Systems Design and Risk-Based Corrective Action

U.S. Army Corps of Engineers, Wetlands Delineation Management (38 hours)

Occupational and Environmental Safety Training (40 hours)

Union Pacific Railroad, Understanding Railroad Cars and Identifying Hazardous Materials

U.S. Envkonmental Protection Agency/Rice University, Subsurface and Ground Water Modeling

U.S. Environmental Protection Agency, Hazard Ranking System Training

Texas Natural Resource Conservation Commission, Texas Risk Reduction Program, Training Program, University of Houston, 2000

Texas Natural Resource Conservation Commission, Soil Sampling and Quality Assurance for Superfund

Texas Water Commission Emergency Response SpiU Training

National Oceanic and Atmospheric Administration, Scientific Training for Oil and Chemical Spills

Security Clearance^ Transportation Workers Identification Card (TWIC) Clearance

eRAILSAFE Clearance

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Chronology January 1987 - December 1988: Visiting Graduate Fellow, Lunar and Planetary Instimte, Houston, Texas

April 1991 -July 1991: Interim Field Service Manager, Anadrill/Schlumberger, Lafayette, Louisiana

July 1989 —Jtme 1992: Senior Field Engineer, Anadrill/Schlumberger, Lafayette, Louisiana and Sugar Land, Texas

June 1992 - August 2001: Texas Natural Resource Conservation Commission (now Texas Commission on Environmental Quality), Houston, Texas

August 2001 - Present: URS Corporation, Houston, Texas

Contact Information URS Corporation 10550 Richmond Avenue, Suite 155 Houston, TX 77042 Main (713) 914-6699 Direct (713) 914-6549 Mobile (281) 226-0862 Fax (713) 789-8404 J ohnny_kennedy@urscorp. com

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Brenda Basile, PhD Principal Scientist

Areas of Expertise Project Management for Superfund and RCRA Sites

Sampling & Analysis Plans (SAPs)

Quality Assurance Project Plans (QAPPs)

Data Quality Objectives (DQO) Planning

Quality Assurance (QA) /QuaUty Control (QC)

RCRA - RFI/CMS

CERCLA Remedial Investigation/Feasibility Study (RI/FS)

Texas Risk Reduction Program (TRRP)

Years of Experience Wirii URS: 8 Years

With Odier Firms: 24 Years

Education PhD/Biochemical and Biophysical Sciences/1978/ University of Houston

BS/Biochemical and Biophysical Sciences/1975/University of Houston

Overview Dr. Basile has over 30 years experience with CERCLA, RCRA, NPDES and analytical programs. She has prepared sampling and analysis plans and quality assurance project plans for RCRA and CERCLA investigations, as well as validated and reviewed analytical and field data. Other areas of expertise include regulatory compliance, data validation and quality assurance/quality control.

Project Specific Experience Site Investigation and Closure Activities

• RI/FS, Malone Service Company Superfund Site (2003-Current). Project Manager for RI/FS. Numerous regulatory parties, including state and federal trustees, USEPA, and TCEQ, participated in the RI/FS. URS implemented the triad approach to the field sampling efforts. Presumptive remedies were developed for the site in a Preliminary Remedial Evaluation Alternatives Report (PRAER). The RI characterized the nature and extent of contamination through representative sampling of various environmental media, including surface and subsurface soils, groundwater, on-site and off-site sediments, on-site and off-site surface water, and waste materials. Contaminants in the environmental media were analyzed using both field screening and laboratory definitive analyses. Additional ecological sampling (sediment and tissue) was conducted for the BERA. Human health (BHHRA) and ecological risk assessments (SLERA and BERA) have been completed for the Site. Treatability studies were conducted to determine the optimum mix for stabilizarion of the sludges. The approved FS evaluated seven alternatives ranging from in-situ stabilization to off-site incineration. The R O D for the Site was approved September 30, 2009. Current activities include storm water management activities which include the operation and maintenance of an underground injection well.

• RI /FS, Chemtronics Superfund Site (2008-Current). Project Manager for oversight of RI/FS conducted by third party consultant. The Site has an active CERCLA remedy (P&T for chlorinated hydrocarbons; caps for historical disposal areas pDAs]) and the remainder of the Site has reentered the CERCLA program. Previous investigations conducted under both the EPA CERCLA program and the D E N R RCRA program have identified VOCs, SVOCs, perchlorate, explosives (nitroaromatics), herbicides, metals, and specialty chemicals in media in the vicinity of the DAs and former operational areas of the Site. URS provides strategy for designing and implementing the R l /FS on behalf of our client to the PRP group. In addition, URS participates in the preparation of the RI /FS deliverables.

• RI T C E Q State Superfund Program, Tucker OH Refinery (2001-Current). Project manager for RI for State Superfund site. The

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Tucker Oil Refinery State Superfund Site is a former refinery that operated from approximately 1940 to 1981. URS is performing a phased RI and related activities to characterize source contaminants and to define the COCs under the requirements of the State Superfund program and TRRP. The site operations resulted in the release of several COCs (including benzene, 1,2-dichloroethane, vinyl chloride, toluene, etc.) to soil and groundwater. Off-site and on-site groundwater is also impacted by free-phase hydrocarbons. The site is adjacent to a municipal drinking water well. A porrion of the site is underlain by a sand channel which controls migration of impacted groundwater and free-phase hydrocarbons from the historical refinery operations and the remainder of the site is underlain by shallow perched sand zones that isolate impacted groundwater from the deeper groundwater. Field activities include the installation of soil borings to delineate soil COCs, cone penetrometer tool (CPT) borings to characterize site stratigraphy and the boundaries of the sand channel. Additional activities include the installation of monitoring wells screened in three zones and the use of field screening analytical procedures (mobile laboratories and immunoassays) to delineate groundwater COCs.

RI and Removal Action, T C E Q State Superfund Program, James Barr Site (2005-Current). Project Manager for RI and Removal Action for site subject to the requirements of the State Superfund Program and TRRP. Field activities include the installation of soil borings and monitoring wells to delineate soil and groundwater COCs. Removal action required removal and disposal of tank contents (sludge) and tank. Deliverables included Field Sampling Plans, Data Usability Summaries (DUS), Removal Action Report, Protective Concentration Level (PCL) Report, Tier 2 Protective Concentration (PCL) Memorandum, Groundwater Monitoring Reports, and Phase I and Phase II Remedial Investigation Technical Memoranda.

Remedial Design, T C E Q State Superfund Program, Archem Site (2008-Current). Project Manager for engineering design of remedial action. Deliverables include Data Quality Objectives Document (DQOD), Air Monitoring Plan, Field Sampling Plan, and Health and Safety Plan as weU as engineering drawings. Remedy includes discharge of surface water to county ditch and excavation and off-site disposal of contaminated soUs and sediments with instimtional control of deed recordation for commercial/industrial use. Project Manager for site maintenance and weU plugging.

RI and Removal Action, T C E Q State Superfund Program, US Liquids Site (2005-2007). Project Manager for RI and Removal Action for site subject to the requirements of the State Superfund Program and TRRP. Prepared work plans and technical memoranda for State approval. Field activities include the installation of monitoring weUs to delineate groundwater COCs, pump tests, water weU survey, site surveying, and removal and disposal of tanks and site clearing.

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Louisiana Refinery, Technical Support for Electrical Resistivity Heating (ERH) Pilot Project. Project involved field-scale demonstration and evaluation of electrical resisrivity heating to treat chlorinated solvents in soU and groundwater to depths of 40 feet. Project included captore and treatment of vapors using alternative vapor treatment processes.

Site-Wide Corrective Action, The Lubrizol Corporation. URS instimted a site-wide, hoUstic corrective action approach replacing the previous SWMU/AOC approach. Task manager for development of COC Ust for the chemical plant. URS and Lubrizol reviewed past site activities, chemical processes, and available toxicity, mobiUty and physical characteristics of numerous site chemicals to develop a COC Ust for future testing and reporting. As part of the work, URS is also evaluating data and providing comments on documents for an adjacent Federal Superfund Site.

Voluntary Cleanup Program, Marathon Boynton Site. A Marathon heritage predecessor company owned and operated a petroleum refinery near the town of Boynton in eastern Oklahoma. A comprehensive site characterizarion at the Site included driUing and soil sampling for lateral and vertical soil assessment, surface water and sediment sampUng in the Lagoon, Ponds, and Unnamed Creek, and instaUation and sampUng groundwater. Task manager for preparation of QAPP, data vaUdation, and COC screening. Prepared Site Characterization Report for submittal to O D E Q .

RI, T C E Q State Superfund Program, Kingsbury Metal Finishing (KMF) Superfund Site. Project Manager for a RI and related activities undertaken to characterize source contaminants and define the namre and extent of COCs in site soUs at the KMF Superfund Site. The site, a former electroplating facUity for zinc and chromium, was investigated using the TRRP requirements. Vertical and horizontal delineation of COCs was completed and " N o Further Action" was recommended. The Site was subsequentiy deleted from the state Superfund registry. URS prepared work plans and a site-specific Health and Safety Plan for three Phases of RI activities. URS characterized the chemical constituents in surface/subsurface soUs for VOCs, SVOCs, cyanide, PCBs, and selected metals. In addition, soU samples were coUected for geotechnical analysis and for site-specific leaching data to assist in the development of Tier 2 PCLs. Vertical delineation to background or the MQL was completed for aU potential COCs. Horizontal delineation to the critical PCL (the lower of the Tier 1 residential •'""'SoUcomb PCL and the Tier 2 residential '̂ '̂''SoUing PCL) was also completed for aU potential COCs.

RI, TCEQ State Superfund Program. Prepared work plans, concepmal site models, quaUty assurance project plans, baseline risk assessment work plans, and data quaUty objectives for multiple state and federal superfund sites. Participated in. site characterization and RI at Jasper Creosoting Superfund Site, North Cavalcade Superfund Site, Baldwin State Superfund Site, and LeveUand Superfund Site.

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RI, French Limited Superfund Group, French Superfund Site. Laboratory manager for organics section analyzing air, sludge and water samples during RI and pUot smdy. Upgradient and downgradient ambient air samples were coUected on Tenax^'^ tabes daUy during pUot stady. Analytical results from the T O - l / T O - 2 analyses were provided to project management within 7 days of sample receipt. Supervised analyses of sludge samples demonstrating the efficacy of the bioremediation pUot stady. Supervised analyses of nearby residential groundwater weUs after flooding of the site by the San Jacinto River.

RFI/BLRA/CMS, Temple-Inland Forest Products. Completed baseline risk assessment (BLRA) and Correct Measures Stady (CMS) for Risk Reduction Rule Standard 3 Closure of Former Creosote Plant. Evaluated chemicals of concern (COCs) in soU and groundwater for industrial and construction worker scenarios, as weU as groundwater ingestion for both industrial workers and potential off-site residents. CMS evaluated corrective action altematives to prevent leaching from subsurface soUs and to prevent human exposure to subsurface soUs and groundwater. CMS recommended N o Action for soUs and Monitored Nataral Attenuation for groundwater.

Voluntary Cleanup Program Investigations and Closures, IBP Inc. Subsurface soUs and groundwater in the vicinity of a former AST at an inactive beef processing and packing faciUty were assessed. Prepared VCP appUcation (including the Site Investigation Report [SIR] and Affected Property Assessment Report [APAR]) that met requirements of newly promulgated TRRP rule. A limited response action was performed and a Response Action Completion Report (RACR) was submitted to the TCEQ. Based on the information provided Ui the reports that demonstrated attainment of the TRRP Remedy A, Tier 1, the T C E Q issued one of the first Certificate of Completions under the TRRP.

RI /FS, U. S. Army Corps of Engineers, Tulsa District. Prepared Chemical Data Acquisition Plan (CDAP), Waste Management Plan and FeasibiUty Stady Workplans for RI/FS at Littie Rock Air Force Base. VaUdated laboratory data and wrote Data VaUdation reports. Performed Bioscreen modeling and risk assessment using ASTM RBCA E-1739 guidelines. Prepared RI and FS reports. Managed subcontractor performing RACER estimates for feasibiUty.

VCP Closure of Brownfields Site, Archstone Properries. Project Manager for environmental oversight of voluntary cleanup of former industrial property. Oversaw excavarion, manifesting and disposal of approximately 20,000 LCY of slag and slag-containing soUs (chemicals of concern were lead and manganese) and asbestos. Prepared RACR for closure under T C E Q Risk Reduction Standard 2 for residential single-famUy future use.

Field Investigations and RCRA Closure Reports, Union Carbide. CoUected soU and groundwater samples for closure reports. Assisted in risk assessment for Standard 3 Closure of Groundwater (With N o

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Further Action) and prepared closure reports and final faciUty closure report for review by TCEQ. AU reports were accepted and faciUty closed under T C E Q RRR Standard 2 and Standard 3 Criteria. Prepared RCRA Environmental Invesrigarion (EI) reports for faciUty submittal to the TCEQ.

Regulatory Compl iance

• SheU Refinery, Waste DeUsting Support (2008-2009). URS provides annual support for the waste deUsting of the hazardous waste landfiU at the Deer Park Refinery. Activities include sampUng and analysis of leachate from the landfiU and the preparation of the annual reports for the EPA Region 6 RCRA division.

• HRVOC QuaUty Assurance Plan Preparation. Chevron PhiUips Chemical Plants, SheU Chemical and SheU Refinery, Enterprise Productions, Marathon Ashland, Rohm and Haas, BaseU. Prepared QuaUty Assurance Plans (QAPs) for refineries and chemical plants containing flares and cooUng towers subject to the subject to a site-wide cap on emissions of highly reacrive volatile organic compounds (HRVOCs)(30TAC115) .

• Wastewater Permitting, Chevron PhiUips and Lamberti. Preparation of TPDES major amendments and permit renewals for chemical plants.

• Emissions Stadies, BP Amoco Refinery, Citgo Refinery, C O N D E A Vista, Goodyear. Prepared sampling plans in conformance with regulatory requirements and coUected process water samples using Method 25D samplers at chemical manufactaring plants for wastewater emissions stady to support H O N and proposed Subpart YYY compUance. Performed detaUed investigations of operating procedures for laboratories located within chemical plants and refineries. Data coUected in the invesrigarions were used to calculate air emissions for Titie V Permit AppUcarions. The laboratories were provided a manual and software for maintaining records for emissions calculations.

• Regulatory CompUance, M.I. DriUing. Reviewed air, water and waste registrations, permits, permit statas and renewal dates for oUfield service company. Developed compUance matrix with a Ust of faciUties, permits, registrations, permit dates, and last regulatory reporting (annual waste summaries, SARA Tier II, discharge monitoring reports) was updated. Performed a limited compUance review to idenrify additional permitting issues. Based on the information coUected about the faciUties, an environmental compUance management package for permit tracking was recommended. Managed disposal of hazardous and nonhazardous waste from laboratory and warehouse faciUties. Prepared waste management plan that aUowed laboratory staff to perform waste management duties in compUance with regulations. Prepared Notice of Intent for Stormwater Discharges for New Mexico faciUty.

• Wastewater CompUance Audit, Valero Refining. Performed wastewater compUance audit for refinery prior to EPA multimedia audit. Assisted internal laboratory with implementing quaUty

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control/quaUty assurance procedures required for NPDES compUance.

• NDPES Regulatory CompUance, SEPCo. Prepared laboratory and sampling requirements for contract laboratories providing NPDES compUance support. Requirements to be used in laboratory bid packages and evaluations. Completion fltud samples were spiked with synthetic driUing mud and submitted to laboratories as blind samples; laboratory performance on oU and grease tests of these samples was evaluated.

• Wastewater and Waste Permitting, Duke Energy. Prepared the Initial Notification and Baseline Monitoring Report for a 520 MW power plant in South Texas aUow discharge of wastewater effluent to POTW. Assisted in negotiation of TPDES permit for faciUty. Prepared notifications and permit appUcations for submittal to regulatory agencies waste disposal. Documents included Initial Notification Package for Hazardous or Industrial Waste Management for submittal to T C E Q and the Notification of Regulated Waste Activity for submittal to EPA Region VI.

• Wastewater Discharge History, Confidential CUent. Process and regulatory histories of petrochemical plant were compUed from faciUty, state and EPA records and used to develop a quaUtarive and quantitative description of the wastewater discharge. The regulatory history of the plant was evaluated. Historical cUscharge data, spUl data and permit data were compUed to calculate the pounds of individual chemicals (metals, volatUes and semivolatUes) discharged. Where historical discharge data were inadequate, estimates of discharge quantities were made from engineering and scientific judgment and interpolation/extrapolation of process-related data.

Laboratory

• ENSR Aquatic Toxicity Laboratory. QA Manager and Laboratory Manager for aquatic toxicity testing laboratory. Laboratory performed acute and chronic NPDES tests of freshwater and marine species. Laboratory performed O E C D testing of products under Good Laboratory Practices. O E C D tests included 28 day-BOD, AmpUsca, Skeletonema, Corophium, and Acartia species. Laboratory also performed toxicity tests of sediments from water bocUes impacted by industrial operations.

• ENSR (AnalytiKEM), Laboratory Management. Managed Organic Analyses section of commercial environmental testing laboratory. Implemented SW-846, NPDES and CERCLA methods for ambient air, soU, water, tissue, vegetation, and hazardous waste samples. Supervised staff of twelve analysts and the operation of 5 GCMS and 5 GC (with ECD, FID and PID detectors). Co-authored quaUty assurance project plans for characterization and remediation of CERCLA and RCRA sites. Developed and implemented GCMS-SIM method for the analysis of polycycUc aromatic hydrocarbons in soU and water samples at a |71,000 cost savings to the cUents. The analytical results were used to support CERCLA site investigations and site remediation activities. Participated in 3-year RCRA FaciUty

002951

URS

Investigation of 432-acre chemical plant including development and implementation of GCMS method for analysis of alcohols and gasoUne range total petroleum hydrocarbons with simultaneous analysis of volatUe organic compounds. Combined methodology was appUed to the analysis of soU and water samples and the avaUabiUty of three results from one analysis saved the cUent over |50,000 in laboratory costs. Managed waste disposal activities for chemical and development laboratories. Submitted annual waste summaries to TCEQ.

• Geochem Research, Volatile and 2378-TCDD Analyses. Supervised extraction and instrumental laboratories analyzing volatUes and 2378-T C D D (dioxin) in soU, water, and hazardous waste samples for Contract Laboratory Program. Analyzed pesticides/PCBs and PAHs in soU, water, and tissue samples coUected to evaluate environmental impact of Corps of Engineers projects. Operated and maintained GC systems, GCMS systems, and spectrophotometers.

Quality Assurance /Qual i ty Control ( Q A / Q C )

• Data VaUdation, Air Liquide, BASF, BP, Chevron, Chevron Pipeline, ConocoPhilUps, Dow, Dupont, Elf Atochem, EU LUly, Kinder-Morgan, Lucent Technologies, M.I. DriUing, Marathon, Motiva, NASA. SheU, Textron, US Navy, USACE, W. R. Grace, TCEQ, Zeneca. VaUdate dioxin/furan and PCB congener data for RI/FS investigations in Massachusetts, lUinois, Indiana, New York and Guam using EPA Region I, Region II and Region III protocols as weU as the Naval Energy and Environmental Support Activity (NEESA) Level D protocols. VaUdate RI /FS, RFI/CMS, and Phase II site investigation data (semivolatUes, pesticides/PCBs, metals, volatiles and general chemistry) for investigations, remedial activities and site closures in Alabama, Arkansas, CaUfomia, Colorado, Florida, Georgia, LotUsiana, Mississippi, New Mexico, North CaroUna, Oklahoma, Rhode Island, South CaroUna, Tennessee, and Texas using EPA, AFCEE, USACE and state protocols.

• Texas Risk Reduction Program, TCEQ. Participation in committees preparing guidance documents for Reporting and Review of COC Concentration Data (TRRP-13), Selection of COCs (TRRP-10), COC Screening (TRRP-14), Data Needs for Tiered PCL Development (TRRP-11) and Pre-assessment Planmng (TRRP-6). The TRRP-13 Guidance document includes minimum laboratory reporting requirements, data vaUdation protocols, data vaUdation guidelines and requirements for data usabiUty reports.

• Texas Risk Reduction Program. Presented training sessions to Texas Chemical CouncU, laboratories and the T C E Q Trade Fair on TRRP 13, assessment planning, data quaUty objectives, and data usabiUty.

• NDPES Regulatory CompUance, M.I. DriUing. Prepared laboratory QuaUty Assurance Manual and standard operating procedures for driUing fltuds company providing offshore permit compUance analyses. Developed in-house training program for CompUance Engineers. Developed form and reports, and trained laboratory

002952

URS

quaUty assurance personnel on review and vaUdation of permit compUance data for synthetic driUing fluids.

• Southern Region QA Manager, ENSR. Provide QA services for offices in ENSR's southern region. Obtained certification for testing and analyses conducted in the State of Loiusiana, maintained and updated State of Florida Comprehensive QAPP. Prepare project quaUty assurance plans, audit subcontract laboratories, and review/vaUdate analyrical data.

• QuaUty Assurance Plan; TRRP GiUdance Document, TCEQ. Assisted T C E Q Superfund QuaUty Assurance group with preparation of a Master QuaUty Assurance Project Plan which directs field and laboratory activities during Remedial Investigation/FeasibiUty Stadies (RI/FS) at State Superfund sites, QAPP included requirements for development of DQOs , field quaUty control, laboratory quaUty control, laboratory reporting Umits for GC, GCMS, metals and general chemistry analyses.

Presentations Ann Strahl, Brenda BasUe, Elaine Higgins, Olga McDonald, and Nan Thomey. Review and Reporting of Chemical of Concern (COC) Concentration Data Under the TRRP Rule. Workshop Presented at the Texas Commission on Environmental QuaUty (TCEQ) Trade Fair, Austin, Texas, May 7, 2003.

Rosemary Martinez, Brenda Basile, and Ron Pitts. TRRP Unraveled The Advanced Course. Technical Seminar Presented at the Texas Chemical CouncU (TCC) / Association of Chemical Industry of Texas (ACIT) Environmental Health and Safety Seminar, Galveston, Texas, June 3, 2003.

Rosemary Martinez, Brenda BasUe, Stephanie Barczyk, and Ron Pitts. TRRP Assessment Planning and Requirements. Technical Seminar Presented at the Texas Chemical CoimcU (TCC) / Association of Chemical Industry of Texas (ACIT) Environmental Health and Safety Seminar, Galveston, Texas, June 9, 2004.

Rosemary Martinez, Brenda BasUe, and Ron Pitts. Texas Risk Reduction Program (TRRP). Technical Seminar Presented at the Texas Chemical CouncU (TCC) / Association of Chemical Industry of Texas (ACIT) Envkonmental Health and Safety Seminar, Galveston, Texas, June 7, 2005.

Sandra Smith, Margaret Roy, and Brenda BasUe. AppUcation of Human Health and Ecological Risk Assessment. Workshop Presented at the 14th International Petroleum Envkonmental Conference, Houston, Texas, November 7, 2007.

Brenda BasUe and Margaret Roy. Evaluating Anthropogenic Background in the Houston-Sugar Land-Baytown MSA. Presentation to Sediment Management Working Group, The Woodlands, Texas, September 29, 2008.

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Specialized Training TCEQ TRRP Training Program - Overview, DetaUed Review and Case Stadies

ERPMIS Trammg (ERPIMS '98 Data Loadkig and ERP Tools P.C. 2.0), Ak Force Center for Envkonmental ExceUence

Envkonmental Analysis Priority PoUutants (American Chemical Society)

Conducting Comprehensive Property Assessments (University of Wisconsin)

Using Envkonmental Statistics to Plan Your Data CoUection Programs (University of Wisconsin)

HAZWOPER 40-hour Health and Safety Tramkig and 8-hour Updates

Vapor Intrusion Pathway: A Practical GuideUne (Interstate Technology & Regulatory CouncU) July 19, 2007

Risk Assessment and Risk Management: Determination and AppUcation of Risk-Based Values (Interstate Technology & Regulatory CouncU) June 19, 2007

Frequentiy Asked Questions and Decision Gtude for Chlorinated Solvents (CLU-In, March 24, 2009)

Perchlorate Remediation Technologies (CLU-In, AprU 28, 2009)

An Improved Understanding of LNAPL Behavior in the Subsurface -State of Science vs. State of Practice (ITRC, October 20, 2009)

LNAPL Characterization and RecoverabUity - Improved Analysis (ITRC, October 22, 2009)

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List of Potential Analytical Laboratories Remedial Investigation

Brine Service Company, Inc. Site Corpus Christi, Texas

1. ALS Environmental Services

10450 Stancliff Road, Suite 210

Houston, Texas 77099

2. Columbia Analytical Services

8540 Baycenter Rd.

Jacksonville, Florida 32256

1317 S 13th Ave.

Kelso, Washington 98626

3. Lancaster Laboratories

2425 New Holland Pike

P.O. Box 12425

Lancaster, Pennsylvania 17605-2425

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Attachment 3

URS Corporation Quality Management Plan

002956

QUALITY MANAGEMENT PLAN

REMEDIAL INVESTIGATION AND FEASIBILITY STUDY

BRINE SERVICE COMPANY SUPERFUND SITE

CORPUS CHRISTI, NUECES COUNTY, TEXAS

PREPARED FOR:

Environmental Protection Agency

on behalf of the

The Brine Service Company

Cooperating Parties Committee

PREPARED BY:

URS

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URS Quality Management Plan

Revision: 2 Date: 11/9/09

Page i of vi

SIGNATURE PAGE

Quality Management Plan

for URS Corporation

Signature

//^ym7/i^J^<fc^h<

Johnny Kennedy, P.O., URS Project Manager

^sicuA Brenda P. Basile, Ph.D., URS Project QA/QC Officer

Donald R. Price, P.G., URS Office QA/QC Officer

J ^ O M S ^ d J i ^

Bruce Broberg, P.E., VP, URS Office Manager

Date:

November 9, 2009

November 9, 2009

November 13,2009

November 13,2009

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^ ^ ^ ^ ^ ^ Quality Management Plan T n S ^ f Revision: 2

Date: 11/9/09 Page ii of vi

DISTRIBUTION LIST

Katrina Higgins-Coltrain, EPA RPM

Johnny Kennedy, P.O., URS Project Manager

Luda Voskov, P.O., TCEQ

Roberto Puga, R.G., Project Navigator, Project Coordinator

Subcontractors

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Page iii of vi

Revision Summary

Revision

1

2

Revision Date

September 2007

November 2009

Revisions

Updated project manager and signature pages for Turtle Bayou (Far West Road) Superfund Site remedial activities

Updated project manager and signature pages for Brine Service Superfund Site remedial investigation/feasibility study. Updated references to URS Quality Management system to 2008 documents. Updated references to EPA Quality Management system documents.

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Page iv of vi

QUALITY MANAGEMENT PLAN TABLE OF CONTENTS

SIGNATURE PAGE i DISTRIBUTION LIST ii TABLE OF CONTENTS iii ABBREVIATIONS AND ACRONYMS vii

1.0 INTRODUCTION 1

2.0 MANAGEMENT AND ORGANIZATION 3

2.1 EPA REMEDIAL PROJECT MANAGER 3 2.2 EPA QUALITY ASSURANCE OFFICER 4 2.3 POTENTIALLY RESPONSIBLE PARTIES 4 2.4 URS QUALITY ASSURANCE OFFICER 4 2.5 URS PROJECT MANAGER 5 2.6 TASK LEADERS 5 2.7 FIELD STAFF 6 2.8 SUBCONTRACTORS 6

3.0 QUALITY SYSTEM AND DESCRIPTION 8

3.1 TECHNICAL ACTIVITIES SUPPORTED BY THE QUALITY SYSTEM 8 3.2 QUALITY SYSTEM COMPONENTS 8

3.2.1 Quality Management Plans 9 3.2.2 Quality Project Plans 9

3.3 QA AND TECHNICAL STANDARD OPERATING PROCEDURES 9 3.4 DATA QUALITY OBJECTIVES PROCESS 9 3.5 MANAGEMENT AND TECHNICAL ASSESSMENTS 10 3.6 LABORATORY QUALITY ASSURANCE PLAN 10

4.0 PERSONNEL QUALIFICATIONS AND TRAINING 12

4.1 TRAINING DEVELOPMENT 12 4.2 INSTRUCTOR QUALIFICATIONS 13 4.3 EVALUATION ' 13 4.4 REGULATORY AWARENESS PROCESS 13

5.0 PROCUREMENT OF ITEMS AND SERVICES 14

5.1 CONTROL OF EQUIPMENT 14 5.2 LABORATORY MANAGEMENT 15

6.0 DOCUMENTATION AND RECORDS 17

7.0 COMPUTER HARDWARE AND SOFTWARE 19

7.1 DATA MAINTENANCE AND STORAGE 19

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Page vof vi

8.0 PLANNING 21

8.1 DATA QUALITY OBJECTIVES 21 8.1.1 Superfund Data Categories 22 8.1.2 Data Assessment Parameters 22

8.2 QUALITY ASSURANCE PROJECT PLANS 23 8.3 FIELD SAMPLING PLAN 24 8.4 ENVIRONMENTAL TECHNOLOGY DESIGN, CONSTRUCTION AND OPERATION QA PROJECT PLANS 25 8.5 HEALTH AND SAFETY PLANS 25

9.0 IMPLEMENTATION OF WORK PROCESSES 29

9.1 RESPONSIBILITY FOR IMPLEMENTATION 29 9.2 MECHANISMS FOR IMPLEMENTATION 29

9.2.1 Standard Operating Procedures 30 9.2.2 Quality Control Checks 30 9.2.3 Data Validation 31 9.2.4 Systems and Performance Audits 32 9.2.5 Inspection Documentation 32

10.0 ASSESSMENT AND RESPONSE 34

10.1 RESPONSIBILITY FOR ASSESSMENTS 34 10.2 IMPLEMENTATION OF ASSESSMENTS 34 10.3 MECHANISMS FOR ASSESSMENT 35

10.3.1 Management System Review 36 10.3.2 Quality System Review 36 10.3.3 Audits and Surveillance ! 36 10.3.4 Independent Technical Review and Peer Review 38 10.3.5 Readiness Review 39 10.3.6 Data Reduction Assessment 39 10.3.7 Data Quality Assessment 40

10.4 RESPONSE TO ASSESSMENTS 41

11.0 QUALITY IMPROVEMENT 42

11.1 NON-CONFORMANCE AND CORRECTIVE ACTION 42 11.2 PROACTIVE QUALITY IMPROVEMENT 43

12.0 TERMS AND DEFINITIONS 44

13.0 LIST OF REFERENCES 53

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^ ^ ^ ^ Quality Management Plan T ^ I S ^ f Revision: 2

Date: 11/9/09 Page vi of vi

FIGURES

Figure 2-1 QA Project Organization 7 Figure 3-1 Quality System Planning Documents 11 Figure 8-1 The Data Quality Objectives Process 27

TABLES

Table 8-1 Quality Assurance Communications Requirements 28

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Revision: 2 Date: 11/9/09 Page vii of vi

ABBREVIATIONS AND ACRONYMS

AOC ASQC C-O-C CQAPP DQO EPA FAR HASP FSP LAN NELAP PIC PM PRP QA QAO QAPP QC QMP RPM SAP SMS SOP URS TL TSA

Administrative Order on Consent American Society for Quality Control Chain-of-Custody Construction Quality Assurance Project Plan Data Quality Objective United States Environmental Protection Agency Federal Acquisition Regulation Health and Safety Plan Field Sampling Plan Local Area Network National Environmental Laboratory Accreditation Program Principal-in-Charge Project Manager Potentially Responsible Party Quality Assurance Quality Assurance Officer Quality Assurance Project Plan Quality Control Quality Management Plan Remedial Project Manager Sampling and Analysis Plan Safety Management Standard Standard Operating Procedure URS Corporation Task Leader Technical Systems Audit

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1.0 INTRODUCTION

Quality Assurance (QA) is an integrated system of management activities involving planning, implementation, assessment, reporting, andquality improvement to ensure that a process, item, or service is ofthe type and quality needed and expected by the customer.

Quality Control (QC) is the overall system of technical activities that measures the attributes and performance of a process, item or service against defined standards to verify that they meet the stated requirements established by the customer; the QC system includes operational techniques and activities that are used to fulfill requirements for quality.

URS Corporation (URS) prepared this Quality Management Plan (QMP) for use on programs and projects managed or sponsored by or under the oversight of the U.S. Environmental Protection Agency EPA (EPA). This QMP documents how URS structures its quality system and describes its quality policies and procedures, criteria for and areas of application, and roles, responsibilities, and authorities. It also describes URS's policies and procedures for implementing and assessing the effectiveness ofthe quality system. The QMP supports EPA's site assessment activities; emergency response activities; prevention and preparedness activities; and technical support activities as they relate to the determination of: 1) the presence of environmental contaminants in areas of potential exposure to humans or the environment, 2) the impacts of environmental contaminants on human health and ecosystems, 3) whether, how, and by whom such threats to human health and the environment should be remediated, and 4) compliance with environmental regulations.

The format and topics addressed follow the guidance presented in EPA QA/R-2 "EPA Requirements for Quality Management Plans" (EPA 2001; Reissued May 31, 2006). Portions ofthis plan were compiled from standard requirements developed by the American Society for Quality Control (American Society for Quality Control (ASQC) 1994). These documents provided not only the materials to establish the framework for the URS Quality System, but also the guidance for establishing QA policies and methods for implementation.

URS has adopted the policy that Quality Systems are established for major contracts that incorporate specific regulatory and contractual requirements. This QMP defines aspects ofthe URS contract-specific Quality System for management oversight of planning, implementing, and assessing environmental programs and for design, construction and operation of engineered environmental systems.

The QMP also provides the framework necessary to create project-specific QA plans that are established to ensure that specifications and data generated and processed to make decisions during assessment, design and construction are scientifically sound, of known and documented quality, and where appropriate, legally defensible. Every attempt is made to achieve these goals in a cost-effective manner commensurate with the needs ofthe EPA and the scope ofthe project.

The QMP is the written directive that is adhered to by URS personnel and team subcontractors. In order to ensure that the plan is adequately implemented in a manner that works toward the success ofthe project, management techniques such as monitoring, review, and auditing are used. To maintain a viable and effective plan, the Quality System itself is subject to annual self or independent review by both program and corporate management.

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Date: 11/9/09 Page 2 of 53

Sections 2.0 through 11.0 ofthe QMP address the 10 Quality System elements identified in EPA QA/R-2.

• . 2.0 3.0 4.0 5.0 6.0 7.0 8.0 9.0 10.0 11.0

Management and Organization Quality System and Description Personnel Qualifications and Training Procurement of Items and Services Documentation and Records Computer Hardware and Software Planning Implementation of Work Processes Assessment and Response Quality Improvement

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Date: 11/9/09 Page 3 of 53

2.0 MANAGEMENT AND ORGANIZATION

QA is accomplished by experienced professionals working across all levels of management and throughout all assignments. The Quality System ensures that data of known quality are evaluated by capable personnel who are trained in the appropriate scientific and engineering disciplines. In addition, senior management oversight is provided to facilitate communication and understanding of EPA needs and to provide a management structure for senior technical oversight and review of individual projects.

The following subsections identify key management positions that have primary responsibilities relating to QA planning, implementation, assessment, design, construction, and operation for URS projects. In addition, specific responsibilities and relationships to other management positions, levels of accountability and authority, and lines of communication are itemized for these key positions. Figure 2-1 presents the QA Project Organization, which includes the EPA and URS QA management staff and any subcontractors.

In accordance with the organizational structure and management methodology established in the QMP for a program. Figure 2-1 presents a typical project-specific organization. This figure shows key positions along with lines of authority and lines of communication and coordination. Descriptions of the responsibilities and authorities for the key positions as they relate to project QA and QC are provided below. It is essential that individuals have defined responsibilities for their functional areas and are clearly aware of the entire project organization and interrelationships. As this is a project organization, senior officials, corporate managers, and agency administrators, whose positions are not functionally involved with data generation, data use, or decisionmaking, are not included.

QA personnel have sufficient authority, access to work areas, and organizational freedom to identify quality problems; to initiate, recommend or provide solutions to problems through established channels; and to verily solution implementation. Such personnel ensure that work, including any processing of information, delivery of products, and installation or use of equipment, is reviewed in accordance with QC objectives and that deficiencies and nonconformances are corrected. QA personnel have direct access to senior management, so that the required authority is provided where needed, to carry out QA duties.

2.1 EPA REMEDIAL PROJECT MANAGER

The EPA-assigned Remedial Project Manager (RPM) is responsible for coordinating project-related activities on behalf of the EPA. A major component ofthis position involves coordinating with the URS Project Manager (PM) and Potentially Responsible Parties (PRPs) in the execution ofthe work and the submission of deliverables as scheduled, in accordance with the Administrative Order on Consent (AOC). Specific responsibilities ofthe RPM are as follows:

• Provide oversight of project activities; • Review and approve project plans (including SAPs) and coordinate review within EPA as necessary. • Initiate the Data Quality Objective (DQO) process as appropriate, providing DQO framework to the URS

PM; • Review and approve the Quality Assurance Project Plan (QAPP);

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Date: 11/9/09 Page 4 of 53

• Ensure that the QAPP and associated reports are transmitted to the EPA Quality Assurance Officer (QAO);

• Transmit comments on QA from the EPA to the PM regarding QA plans and laboratory performance; • Ensure that the PM addresses EPA review comments and takes appropriate action; • Transmit program-wide quality issues to EPA Quality Assurance Officer (QAO); and • Initiate field and laboratory audits and management system reviews.

2.2 EPA QUALITY ASSURANCE OFFICER

The EPA QAO or designee is responsible for ensuring that the project has an appropriate QA program. Specific responsibilities ofthis position are to support the EPA RPM on QA issues.

2.3 POTENTIALLY RESPONSIBLE PARTIES

The PRPs provide oversight and advice to the URS Project Manager and coordinate the execution ofthe AOC. These responsibilities are conducted through a committee established by the cooperating parties to the AOC. Day-to-day administration ofthe project may be delegated to a Project Coordinator. Specific responsibilities of the PRPs (or the Project Coordinator) are as follows:

• Provide oversight of project activities; • Review and comment on project plans (including SAPs and QAPPs); • Ensure that URS addresses EPA review and quality assurance comments and takes appropriate corrective

action; and • Document adherence to the AOC schedule and completion of activities scheduled in the Scope of Work.

2.4 URS QUALITY ASSURANCE OFFICER

The URS QAO communicates with the URS PM and URS Task Leaders (TL) and additionally has direct reporting access to the URS Corporate QA Director on quality-related matters. The QAO is responsible for the development, implementation and maintenance ofthe comprehensive URS Quality System. Responsibilities of this position include communicating with program and project management to ensure that a quality product is produced for delivery. Project-specific responsibilities ofthe QAO or designee are as follows:

• Serve as the official contact with EPA for QA matters related to the AOC; • Respond to QA needs, resolve problems, and answer requests for guidance or assistance; • Prepare the generic QAPP, and revise as necessary; provide guidance to the PM in the development of

project-specific SAPs; • Review and approve the project-specific SAPs; • Together with the PM, assign competent, qualified Independent Reviewers to review the technical

adequacy of deliverables; • Track the progress and completion ofthe review and approval process; • Ensure that EPA protocols and procedures, as well asURS Standard Operating Procedures (SOPs), are

being followed; • Review the implementation of selected SAPs and the adequacy ofthe data or products generated based on

quality objectives;

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Date: 11/9/09 Page 5 of 53

• Initiate field and laboratory audits and management system reviews; • Maintain a current list of approved QAPPs, SAPs, and SOPs to be used for auditing purposes; • Authorize, coordinate, and conduct intemal and subcontractor audits of selected projects for adherence to

the project plans. • Submit notice ofany laboratory and field systems audits prior to their occurrence and in a timely manner

to the EPA QAO who has the option to attend; • Review audit and nonconformance reports to detennine areas of poor quality or failure to adhere to

established procedures; • Confer with the audited entity on the steps to be taken for corrective actions and track nonconformance

until it has been corrected; evaluate the adequacy and completeness ofthe action taken; confer with the PM or TL to resolve an inadequate corrective action; confirm the adequacy and the implementation ofthe response action;

• Suspend or stop work with the concurrence ofthe PM, TL, and EPA, upon detection and identification of an immediate adverse condition affecting the quality of results;

• Provide training on QA policies, procedures, and methodology;

2.5 URS PROJECT MANAGER

The URS PM reports to the Principal-in-Charge (PIC) and is responsible for providing senior leadership and

expertise to individual TL. Responsibilities ofthe PM are to:

• Identify the need and expectations of services to be provided and when necessary, negotiate acceptable scopes ofwork;

• Provide senior level input and technical expertise to TLs on developing or establishing project objectives, data quality objectives, sampling rationale, regulatory requirements, and data assessment methods;

• Ensure that the best available technology is being applied to reduce potential waste and inefficiencies, and that the best known processes are in use;

• Perfonn readiness reviews and monitor the progress ofwork in relation to scope, cost, and schedule; • Provide senior level coordination, review, and approval of project documents; • Provide review of in-house project-specific models and programs prior to their use; • Assess completion ofwork in accordance with EPA and regulatory requirements; • Provide full assistance to the URS QAO and audit team during the planning, scheduling, and management

of project-specific QA audits and surveillance; review assessment findings; and ensure that required corrective actions are completed;

• Confer with PM on activity-specific issues; and • Refer quality problems and concems to the URS QAO for investigation and/or resolution.

2.6 TASK LEADERS

The TLs are responsible for monitoring and documenting the quality ofwork produced by the project team, which includes the URS field staff and subcontractors. The fundamental goal ofthis position is to produce a quality work product within the allotted schedule and budget. Duties include executing all phases ofthe project and efficiently applying the full resources of the project team in accordance with the project plans. Specific responsibilities ofa TL are as follows:

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Date; 11/9/09 Page 6 of 53

Assist with determining DQOs. Prepare and implement the project SAPs (which incorporate applicable QAPP elements) and reports for each project, as appropriate; Ensure that SOPs are available and in use for activities that affect product quality and that assigned staff have been trained in their implementation; Inspect and accept supplies and consumables; Ensure that appropriate sampling, testing and analysis procedures are followed and that correct field laboratory quality control checks are implemented; Monitor sample preservation, handling, transport and custody throughout the project; Coordinate the appropriate disposition of investigation-derived waste; Ensure that the proper number and type of environmental and control samples are collected, identified, tracked, and sent to the laboratory for analysis; Coordinate and schedule sample shipment to analytical laboratories to meet holding times and analytical procedures specifications; Monitor team and subcontractors for compliance with both project and data quality requirements records, costs, and progress ofthe work; replan and reschedule work tasks as appropriate; Review and approve calculations to ensure that data reduction is performed in a manner that produces quality products; Verify data quality, test results, equipment calibrations, and QC documentation; maintain and regularly review QC records; Ensure that key decisions and project deliverables are subjected to independent technical review by qualified personnel within the time frame ofthe project schedule; Plan and schedule assessments in conjunction with the QAO and PM; Provide full assistance to the audit team during the conduct of project-specific QA aiidits. Review and respond to assessment findings; determine the root cause for the non-conformance; confer with the QAO on the steps to be taken for correction; and ensure that procedures are modified to reflect the corrective action and that they are distributed to field personnel, including subcontractors; and

• Report QA problems to the PM and QAO.

2.7 FIELD STAFF

Under the direction ofthe TL, the Field Staff are responsible for the planning, coordinating, performing, and reporting of specific technical tasks. Responsibilities ofthe Field Staff are as follows:

• Implement the generic QAPP and project-specific SAP; • Develop and maintain technical activity files and log books; and • Implement technical procedures applicable to tasks.

2.8 SUBCONTRACTORS

URS personnel may delegate to others the responsibility of planning and executing certain portions ofthe project activities. When subcontractors are involved in activities covered by the requirements ofthe generic QAPP, the responsibility and authority of each subcontractor must be clearly established and documented. TLs are responsible for monitoring subcontractors for compliance with both project and data quality requirements.

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URS Figure 2-1 QA Project Organization

Quality Management Plan Revision: 2

Date: 11/9/09 Page 7 of 53

USEPA Remedial Project Manager (RPM)

USEPA Quality Assurance Officer (QAO)

~i

Potentially Responsible Parties (PRPs)

Project Navigator Project Coordinator

URS Principal-in-Charge (PIC)

URS Quality Assurance Officers (QAO)

URS Project Manager (PM)

Subcontractors Quality Assurance Officers

URS Task Leader

Subcontractors

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Date: 11/9/09 Page 8 of 53

3.0 QUALITY SYSTEM AND DESCRIPTION

The Quality System is implemented through systematic planning and assessment of activities undertaken by URS and includes provisions to ensure that the products or results of environmental projects are ofthe type and quality needed and expected by the EPA (Figure 3-1). QA/R-2 describes the two levels of management controls contained in the Quality System:

• Organizational level: Activities that support common or standardized functions fall under management systems at the organizational level. These functions establish the QA framework for performing work.

• Technical/project level: The technical or project level consists ofthe project-specific Quality System QA activities necessary to produce the desired type and quality of product defined at the organizational level.

3.1 TECHNICAL ACTIVITIES SUPPORTED BY THE QUALITY SYSTEM

The URS Quality System supports the three general types of activities to be performed by URS. These activities include:

• Site Assessment: Investigation, site characterization, ecological assessment, historical data evaluation, feasibility studies;

• Remedial Response: Removal Support, Engineering Evaluations and Cost Analyses; and

• Technical Support: Analytical Services, treatability studies, public participation support environmental/ecological evaluations, project work plans, and assessment of human health and ecological risks.

In order to fulfill the requirements of these technical activities. The URS Quality System provides for

Training and development of staff; Assignment of personnel with relevant knowledge and experience for the specific task; Clear delineation of responsibilities and empowerment; Effective communication within the team, team partners, and the EPA throughout the project; Continual development of SOPs based on updated standards and guidelines; Independent technical reviews and audits for compliance with project plans, specifications, designs, procedures and regulatory requirements; and

• Corrective action taken when deviations from quality objectives are identified.

3.2 QUALITY SYSTEM COMPONENTS

EPA guidance documents, professional publications, URS corporate plans, and/or handbooks describe many of the components needed to implement the Quality System. Based on these references, URS has developed written plans, procedures and assessments for implementation ofthe URS Quality System. An overview ofthe primary components is presented below and summarized in Figure 3-1.

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3.2.1 Quality Management Plans

The Qualitv Management Plan (QMP) (this document) describes the QA organizational stmcture, policies and procedures, functional responsibilities, levels of accountability and authority, and necessary interfaces associated with the URS Quality System. The QA policy and goals described in the QMP apply to activities conducted by URS personnel and subcontractors. The QMP provides the blueprint for how URS plans, implements and assesses its Quality System.

3.2.2 Quality Project Plans

The site assessment Quality Assurance Proiect Plan tOAPP)) presents the policies, organization, objectives, functional activities, procedures, and specific QA and QC activities, designed to achieve DQOs established for site assessment projects. The QAPP documents the framework for determining DQOs or acceptance criteria for a project, identifying the critical measurements to be performed, and discussing the QA activities to be conducted during the sampling, analytical, and validation phases ofthe project. Further discussion of QAPP requirements can be found in Section 8.2.

Project-specific Field Sampling Plans (FSPs) are developed for discrete sampling events performed under the site assessment program in accordance with EPA guidance (EPA 1988). The FSP presents the project background, description, specific DQOs, the sampling program to be employed, the project organization, and required QA procedures and reports. Further discussion of FSP requirements can be found in Section 8.3.

A Removal Qualitv Assurance Proiect Plan outlines the methods by which a removal design and construction project is measured and controlled to ensure the desired level of performance (EPA 1989). Specific information pertaining to removal QAPPs is presented in Section 8.4.

Site Health and Safetv Plans (HASPs) are developed as directed and in accordance with the FSP and the URS Safety Management Standards (SMS).

3.3 QA AND TECHNICAL STANDARD OPERATING PROCEDURES

QA and technical SOPs have been compiled for environmental information and data gathering activities; repetitive tests and measurements; and inspection and maintenance of facilities, equipment, and services. Additional procedures are prepared as needed to address any new activities associated with the URS scope of work.

SOPs are developed whenever it becomes necessary to standardize routine tasks or activities. Procedures developed in support ofthis contract are clear, concise, and informative and use a standardized format. Sources of sampling and analyfical methods used to prepare associated procedures are listed in the references. Further discussion of SOP development can be found in Section 9.2.1 ofthis plan.

3.4 DATA QUALITY OBJECTIVES PROCESS

It is the goal of EPA to collect data of sufficient quantity and quality to support defensible decision-making. At the same time, it is necessary to minimize expenditures related to data collection by eliminating unnecessary, duplicative, or overly precise data. In order to accomplish both of these goals, the objectives ofthe project, i.e.,

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the type, quality, and quantity of data necessary to address the problem, are identified at the beginning of the project using the DQO process. Further discussion ofthe DQO process is provided in Section 8.1.

3.5 MANAGEMENT AND TECHNICAL ASSESSMENTS

Assessments are conducted to increase management and technical staff understanding ofthe Quality System and to provide a basis for improving the system. Assessments may take two forms:

• Management and technical self-assessment, performed by someone responsible for overseeing and/or performing the work; and

• Management and technical independent assessment, performed by someone outside of the group performing the work.

Additional information on assessments and assessment tools (e.g., reviews, audits, surveillance) is provided in Section 10.

3.6 LABORATORY QUALITY ASSURANCE PLAN

The Laboratory QA Plan is a written description ofthe overall program of QA used by the laboratory to ensure that quality analytical data are generated. The plan describes the techniques the laboratory uses to control analytical processes, ensure calibration and measurement accuracy, and control samples and data throughout the laboratory. Further discussion of requirements for Laboratory QA Plans is provided in Section 5.2.

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Figure 3-1 Quality System Planning Documents

EPA Guidance Documents

EPA Order 5360.1, Policy and Program Requirements to Implement the Mandatory Quality Assurance Program

EPA Requirements for Quality Management Plans (EPA QA/R-2)

EPA Requirements for Quality Assurance Project Plans for Environmental Data Operations

(EPA QA/R-5)

Quality System Management Plans

Management Plan Quality Management Plan

Quality Project Plans

Site Assessment Quality Assurance Project Plan Field Sampling Plan QA/QC Sampling Plan/ Work Plan Removal Quality Assurance Project Plan Site Health & Safety Plan

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4.0 PERSONNEL QUALIFICATIONS AND TRAINING

The PM ensures that assigned program personnel (including subcontract personnel) performing tasks and functions related to data or product quality have the necessary education, experience, and training.

URS personnel are required to maintain appropriate qualifications for the duration of the project, including necessary federal/state certifications and requirements. The PM establishes the means (such as continuing education and peer reviews) to ensure that personnel (including managers and technical staff) demonstrate and maintain proficiency in performing their assigned work. Quality management training provides managers and technical personnel with a working understanding ofthe Quality System, along with the tools and techniques necessary to enable their full participation in planning, implementing and assessing Quality System components.

Training occurs for three of the URS activity categories: site assessment, remedial response, and technical support. Specific training needs are identified and prioritized and training is scheduled by the QAO, or PM based on both the immediate need of ongoing projects and the projected needs of future projects. Training needs are also identified by actual performance on the job as revealed by ongoing quality reviews that indicate performance deficiencies resulting from a lack of knowledge or skill. Training is continually reassessed, updated and implemented.

Most training is accomplished through mentorship of less experienced staff by fully trained and experienced supervisors and staff This training occurs in the URS office and in the field. Group cross-training sessions are scheduled as time permits, to provide staff members the opportunity to enhance their skills and to ensure that sufficient experienced staff are available to accomplish a wide variety of tasks. Selected personnel participate in quality-related seminars, short courses, and professional meetings. In addition, continued professional development is encouraged through tuition assistance, and attendance at conferences and professional society meetings.

The QAO has overall responsibility for conducting QA training that includes both initial orientation and ongoing presentations. This approach is designed to maintain a high degree of awareness of QA methods, planning steps, guidance documents, and reporting requirements. Update training sessions are held when major revisions to the QMP, QAPP, or SOPs are made. Training updates may take the form of written memoranda. Training records are kept by the QAO indicating the training attendance, qualifications, certifications, method and extent of each staff member's training. These records are maintained within personnel files.

4.1 TRAINING DEVELOPMENT

Training programs take accepted instructional design principles into consideration as follows:

• Task analysis to identify specific skills needed to perform the task and for the underlying knowledge or skill that supports task performance;

• Review of objectives to ensure changes required by task analysis findings are incorporated. The objectives specify training outcomes;

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• Analysis of intended participants to ensure training development considers their entry level skill, knowledge, interests, prior experience, and leaming styles;

• Identification of prerequisite skill and knowledge to determine how the content and instructional events are organized, ensuring that instruction proceeds logically from the known to the unknown;

• Selection of instructional methods and media to most effectively conduct the training. Typically, there is a combination ofthe methods of lecture, discussion, demonstration, simulation, and role-play. Supervised leaming on-the-job, as well as computer-based training or interactive video displays, are

also considered when they are likely to be more effective or if there are only a few participants for training. Media selection is based on the objectives, instructional content, and overall instructional strategy;

• Evaluations during and at the end of training. Evaluations are designed to ensure that expected training outcomes are measured, as well as to provide feedback to the participants;

• Revision of content based on the evaluations and new job conditions that require revision in instructional content; and

• Use of appropriate off-the-shelf course work or outside sources, such as universities or training vendors, when internal development is not the most effective strategy.

4.2 INSTRUCTOR QUALIFICATIONS

Instructors are subject matter experts who have either developed the training or received instruction on how to train. They are observed by supervisors when they first conduct training and periodically thereafter. Instructors who require certification must have such certifications, and keep them active, before they are allowed to serve as instructors. Instructors are hired, or they are employees who are assigned instructional duties because of their knowledge and skill. Subject matter experts are approved by the PM for prerequisite education, training or certification, as well as instructional ability, before becoming instructors. Training materials are reviewed by the appropriate supervisor to ensure the material is current and revisions are made as appropriate.

4.3 EVALUATION

Transfer of training to the job is monitored by follow-up evaluations after the employees retum to their respective jobs and by review of Performance Evaluation Ratings. The evaluations are made by the QAO and other management staff who are responsible for the work being evaluated. Training programs may be revised in response to the various training evaluations.

4.4 REGULATORY AWARENESS PROCESS

URS staff members are required to maintain regulatory awareness in their respective technical areas. To fulfill this requirement, URS maintains on-line subscriptions to BNA Environmental Reporter, regulatory databases, and subscriptions to a wide variety of environmental journals and newsletters.

URS technical personnel are 40-hour OSHA certified and receive annual 8-hour refresher training that includes updates on newly enacted legislation and regulations.

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5.0 PROCUREMENT OF ITEMS AND SERVICES

The procurement of purchased items and services is planned and controlled to ensure that the quality ofthe items and services is known, documented, and meets the requirements and expectations ofthe EPA and the Federal Acquisition Regulations (FAR). Section 6.4 of the URS Quality Management System Policy (URS 2008) describes the quality requirements associated with procurement.

As a part ofthe procurement qualification process, subcontractors who provide services or items that directly affect the quality of results or products from environmental programs are required to establish and implement QA plans and operating procedures consistent with EPA QA requirements. The laboratory QA Plan is an example of a document required by the procurement process that demonstrates a laboratory's ability to generate quality data. In addition, subcontractor deliverables must meet established QA criteria based upon objective evidence of performance. TLs are responsible for continual monitoring of subcontractor compliance with QA requirements. Finally, subcontractors are subject to periodic audit to substantiate compliance.

Supplies, equipment, and services are evaluated, selected, and maintained by the Equipment Manager and TLs to meet project quality goals. Facility surveys, equipment performance evaluations, subcontractor qualifications, and quality record reviews are among the methods that are employed to measure against established performance standards.

5.1 CONTROL OF EQUIPMENT

Equipment and instruments used for the URS program are calibrated, adjusted, and maintained to operate within manufacturers' specifications and SOPs. These procedures are performed to maintain the necessary accuracy, precision, sensitivity, and traceability for making reliable measurements or collecting representative samples. This effort is conducted by trained technicians using service manuals or through service agreements with a qualified maintenance contractor. Calibration and maintenance schedules and records are maintained for the equipment. Both equipment and equipment records are located in a controlled access facility when not in use.

Guidelines for the calibration, adjustment, maintenance, inspection and testing of equipment are documented in equipment-specific SOPs that address topics or reference an operating manual containing the following information:

Operational theory; Inspection and testing; Functional checks and adjustments; Calibration; Special environmental conditions or interferences; Routine and corrective maintenance; Decontamination; Deactivation and storage; Equipment records; and Simplified operational instructions.

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Preventive maintenance, based on the type of equipment, stability characteristics, required accuracy, intended use, and environmental factors (such as, temperature, humidity, etc.) is implemented on a scheduled basis to minimize downtime and to ensure accurate measurements from both field and laboratory equipment. Equipment that is identified to be out-of-calibration or malfunctioning is removed from operation until re-calibrated or repaired. In addition, backup equipment and critical spare parts are maintained to quickly correct equipment malfunction.

5.2 LABORATORY MANAGEMENT

URS provides guidelines to ensure that laboratories procured through subcontracts meet requirements for a QA program that facilitates the generation of valid data of known and acceptable quality. This goal is accomplished through one or more of the following: review of laboratory QA plans and SOPs; examination of existing laboratory accreditations; analysis of performance samples; and laboratory inspections and audits prior to environmental sample analysis. Proper communication of analytical QC requirements prior to sample analysis and establishment of plans for maintaining the QC program during the course ofwork are important contributors to quality data.

Each subcontracted laboratory is required to submit for review, a Laboratory QA Plan that describes the approach to ensuring that quality data are generated from sample analysis. The Laboratory QA Plan includes the following topics:

Title page with approval signatures; Laboratory organization and personnel responsibilities; Personnel qualifications and training; Laboratory facilities and equipment; Equipment maintenance; Material procurement and control; Sample handling and chain of custody; Calibration procedures; Analytical procedures; Limits of detection; Analysis and documentation of QC samples; Data assessment procedures for accuracy and precision; Data evaluation and data reduction; Out-of-control events and corrective action; Intemal laboratory audits; Document control and archiving; and QA reports.

Programs and laboratory accreditations such as the National Environmental Laboratory Accreditation Program (NELAP) have most elements ofthe laboratory approval process in place. Documentation from these programs may be used in place of conducting the corresponding approval task.

When a laboratory is required to demonstrate its ability to successfully analyze performance samples, this may be

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accomplished through providing documentation of recent proficiency testing results conducted by an independent reviewer (preferably a govemment agency) using standard EPA-approved analytical methods. Otherwise, prior to beginning analysis of field-collected samples, the laboratory may analyze a performance sample for chemical substances representative of those anticipated in environmental samples. The purpose of proficiency testing is to determine laboratory proficiency with sample analysis designed to simulate environmental field conditions.

Under certain circumstances, an inspection of actual laboratory operations or an audit of laboratory methods and procedures is conducted. Circumstances that would cause on-site inspections or audits would typically involve concems of laboratory performance or practices, verification of laboratory capabilities, observation of laboratory practices and adherence to QA guidelines, or difficuhies in satisfactorily achieving the other steps in the laboratory approval process.' Overall, the purpose of laboratory inspection is to verify that the established QC requirements are being met by the routine operation ofthe laboratory. Four steps are involved in this process, as follows:

• Overview and Orientation - Discussing with laboratory personnel the objectives and schedule ofthe on-site inspection or audit;

• Observation, Examination, and Review - Witnessing actual analytical procedures, following the steps for sample handling and storage, examining QC records and control charts, and reviewing corrective action reports for out-of-control events;

• Findings - Conducting an exit interview that details the results ofthe on-site inspection or audit and identifying deficiencies to be addressed by corrective action; and

• Corrective Action - Reviewing the plan prepared by the laboratory that addresses the deficiencies identified by inspection.

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6.0 DOCUMENTATION AND RECORDS

The PM is responsible for ensuring that effective document control procedures are established, implemented, and maintained. Document control is a management tool used to establish a thorough record of project activity that includes (but is not limited to) correspondence, deliverables, receipts and invoices, technical data, and anything else that is deemed important for project documentation and historical reference.

The URS document control system begins with identifying, preparing, reviewing, approving, and distributing pertinent documents and records. The responsibilities for each of these activities are defmed throughout this QMP as they apply to program and project planning and assessment. Generally the PM and QAO prepare program documents and the TLs prepare project documents. Reviews are accomplished by independent and peer reviewers. Approval authority lies with the QAO and the PM (refer to Section 10.3.4, Independent Technical Review and Peer Review).

The Quality System requires that documentation be legible, dated (including revision dates), clean, readily identifiable, and maintained in an orderly manner. Where evidentiary records are involved, the maintenance of records also includes establishing and implementing appropriate chain of custody and confidentiality procedures for the affected records.

Active controlled documents are maintained either in the URS office that has restricted access or in a secured off-site storage facility that is designed to ensure document protection, preservation, traceability, and retrievability. Accounting and procurement documents are controlled by their respective departments. In-progress technical data and project documents are controlled by the TLs. Administrative documents are controlled by the Administrative Assistant.

The requirements for long-term controlling and archiving of original documents are based on URS policy requirements, or as specified by EPA. While in storage, records are protected from damage, loss, and deterioration.

Documents and records that are controlled include:

QA Project Plans;

Field Sampling Plans; Site Health and Safety Plans; Quality Assurance Reviews; Response to Comments; Calculation Sheets; Drawings

Standard Operating Procedures;

Technical Memoranda; Draft and Final Reports; Design specifications; Blueprints; and Independent Technical Reviews/comment

In addition, the following documents are controlled to reflect the achievement of the required quality for completed work and/or to fulfill any statutory requirements. These documents may be in the form of printed and electronic media as specified, and include:

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Field logs and measurements; Instrument test data; Calibration data; QC data; Inspection results; Materials testing results;

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Technical and readiness reviews results;

Cost estimates; Design assumptions and calculations; Construction submittals, plans, and schedules; Record drawings; Assessment results; and Data usability results.

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7.0 COMPUTER HARDWARE AND SOFTWARE

The URS Computer hardware/connectivity system consists ofa URS work station host server, a URS Local Area Network (LAN), and desktop and portable PCs and printers. Requests for procurement of new hardware must include an evaluation ofthe effect ofthe changes on program and project performance.

Both URS and EPA licensed software are available. The initiator ofa request for new or adaptations of existing software must thoroughly document the intended use and required interfaces. Computer programs available include but are not limited to design, design analysis, modeling of environmental processes and conditions, operations or process control, and data bases or document control registers.

Software proposed for purchase is approved by the PM and the Office Manager, and is consistent and compatible to the extent possible with EPA software and applications. Prior to purchase or development, software is evaluated for:

• Compatibility ofthe hardware/software combination; and • Suitability ofthe software to the project need.

Intemally developed applications related to accounting, equipment inventory and other project specific tasks follow an approved software development methodology. Intemally developed applications include:

• Operating instructions for the program; • Description of program computations, including simulation limitations, as applicable; and • Information to allow future modification ofthe program.

Intemal application documentation includes, but is not limited to:

Software identification including version status; Program application and limitations; Hardware compatibility requirements; Application test data set and associated output; and Verification determination.

An application test data set, associated output, and verification determination is developed and performed for purchased software and spreadsheets to assure that engineering and data calculations obtained from that software are accurate. At a minimum, a calculation sheet is completed confirming, via hand calculation, the results of spreadsheet computations (refer to Section 10.3.6). Software audits are conducted to ensure that software is properly licensed.

7.1 DATA MAINTENANCE AND STORAGE

In order to maintain quality data, computer virus protection software is utilized on PCs. Electronic files acquired from outside the URS office are scanned before use.

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Most documents and data files are stored on the URS LAN server. Files on that system are backed up daily, weekly and monthly. These backups capture database files, documents and user files.

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8.0 PLANNING

The URS PM and TLs are responsible for planning work involving the generation, acquisition, and use of environmental data or information. The type and quality of environmental data or information needed are defined and documented using a systematic planning process, DQOs. The project-specific planning includes the PRPs, EPA RPM or other EPA contact that has requested the data or information, as well as the URS technical staff responsible for obtaining, analyzing, and evaluating the data. TLs are responsible for guiding and ensuring that planning activities are documented, and that participants are informed of and understand completely the requirements ofthe project. Results of planning activities are subject to review by EPA and URS management for conformance to technical scope and quality expectations. Project planning for information and data collection and evaluation includes:

• Definition of project/task scope, technical objectives and quality goals and the desired action or result from the work;

• Identification of parties (in addition to EPA and URS personnel) that need to participate in the project and their role in planning, implementation, and assessment activities;

• Identification of unique planning requirements based on the applicable environmental programs; • Identification ofthe required information or data to achieve the desired action or result; • Identification of QA and QC requirements to establish the needed quality and quantity of the

information or data collected or produced to support decision-making. Determination of data quality indicators, acceptable level of confidence, statistical assessment of uncertainty, and level of data validation and verification needed.

• Identification ofthe extent ofdocumentation needed to adequately describe the quality ofthe results; • Identification of required personnel skills, technical disciplines, and types of equipment; • Identification of special applicable regulatory requirements; • Consideration of budget and scheduling constraints; • Determination of assessment tools needed to ensure that project goals and objectives are being met

(e.g., independent technical reviews, peer reviews, field inspections, readiness reviews, and technical audits);

• Identification of methods/procedures for storing, analyzing, and reporting the data produced based on the intended use of the data; and

• Identification of possible methods/procedures (including waste minimization objectives) for testing and disposing of contaminated sample material that may be accumulated during the project.

Table 8-1 summarizes QA document requirements including responsible initiators and review requirements.

8.1 DATA QUALITY OBJECTIVES

It is the goal of EPA and the regulated community to minimize expenditures related to data collection by eliminating unnecessary, duplicative, or overly precise data. At the same time, it is necessary to collect data of sufficient quantity and quality to support defensible decision-making. The most efficient way to accomplish both of these goals is to begin each project by implementing the DQO Process (Figure 8-1) and by ascertaining the type, quality, and quantity of data necessary to address site-specific problems (EPA 2006). It is the responsibility

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ofthe PM, in conjunction with the QAO, to implement the DQO process as part ofthe project planning activities.

8.1.1 Data Categories

These data categories are associated with specific QA and QC elements, and may be generated using a wide range of analytical methods. The particular type of data to be generated depends on the qualitative and quantitative DQOs developed .during applicafion ofthe DQO Process.

Screening Data with Definitive Confirmation: Screening data are generated by rapid, less precise methods of analysis and less rigorous sample preparation. Screening data provide analyte identification and quantification, although the quantification may be relatively imprecise. At least 10% ofthe screening data are confirmed using analytical methods and QA/QC procedures and criteria associated with definitive data. Screening data without associated confirmation data are not considered to be data of known quality.

Definitive Data: Definitive data are generated using rigorous analytical methods, such as approved EPA reference methods. Data are analyte-specific, with confirmation of analyte identity and concentration. Methods produce tangible raw data (e.g., chromatograms, spectra, digital values) in the form of paper printouts or computer-generated electronic files. Data may be generated at the site or at an off-site location, as long as the QA/QC requirements are satisfied. For the data to be definitive, either analytical or total measurement error must be determined.

8.1.2 Data Assessment Parameters

Site-specific acceptance criteria are established for each ofthe five data assessment parameters identified by the EPA. These objectives are expressed as quantitative and qualitative statements conceming the type of data needed to support a decision, based on a specified level of uncertainty. Data are reconciled with stated DQOs by calculations for accuracy, precision, and completeness, and statements on representativeness and comparability. The data assessment parameters are:

Precision is a measure of mutual agreement among replicate (or between duplicate) or collocated sample measurements ofthe same analyte. The closer the numerical values ofthe measurements are to each other, the more precise the measurement. Precision for a single analyte is expressed as the relative percent difference of replicate or collocated samples. Tools for demonstrating the precision ofthe measurement process are replicate samples, collocated samples, inter/intra laboratory testing, instrument checks.

Accuracy is a measure of bias in a measurement system. The closer the value ofthe measurement agrees with the true value, the more accurate the measurement. Accuracy is expressed as the percent recovery ofthe surrogate or spike analyte from a sample or standard. Accuracy is dependent on traceability of instrumentation, standards, samples, and data; methodology; reference or spiked samples; performance samples; and equipment calibration.

Completeness is a measure ofthe number of valid measurements obtained in relation to the total number of measurements planned. The closer the numbers are, the more complete the measurement process. Completeness is expressed as the percentage of valid-to-planned measurements. A sufficient volume of sample material is collected to complete the required analyses, so that samples represent possible contaminant situations under investigation as well as background and control areas. Completeness is influenced by environmental conditions, potential for change with respect to time and location, equipment maintenance, data records, sampling location.

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sample volume, QC samples, and sample representativeness.

Comparability is a qualitative parameter expressing the confidence with which one data set can be compared to another. The comparability goal is achieved through the use of SOPs to collect and analyze representative samples, by reporting analytical results in appropriate and consistent units and by maintaining consistency in sampling conditions, selection of sampling procedures, sample preservation methods, and analytical methods.

Representativeness is a qualitative parameter that expresses the degree to which sample data accurately and precisely represent a characteristic ofa population, parameter variations at a sampling point, or an environmental condition. The design of and rationale for the sampling program (in terms ofthe purpose for sampling, selection of sampling locations, the number of samples to be collected, the ambient conditions for sample collection, the frequencies and timing for sampling, and the sampling techniques) ensure that environmental conditions have been sufficiently represented.

8.2 QUALITY ASSURANCE PROJECT PLANS

The QAPP is the documentation resulting from the DQO Process for projects that require environmentally related measurements. The QAPP ensures that the required level of data quality is established at the beginning ofthe project and that data generated and processed are ofthe quality and integrity required. The QAPP is used at three fundamental phases during the execution ofa project:

• Project start-up planning allowing EPA and URS personnel an opportunity to prepare and review plans from a QA viewpoint;

• Throughout the project, as a guide for real-time QA reviews and audits; and

• Project closeout, as a basis for assessing whether the project attained the stated goals.

The QAPP presents detailed quantitative targets for the quality of the sampling, laboratory analysis, and data review and describes the methodology used to ensure that the targets are met. The QAPP facilitates appropriate quality collection and assessment of data. The PM is responsible for preparing the QAPP. The QAO or designee with the concurrence with the PM, assesses the QAPP, recommends changes, and approves QAPPs.

The content and level of detail in each QAPP varies according to the nature ofthe work and the intended use of the data. Because ofthe diversity in the type ofwork being provided and the intended use ofthe data, a graded approach to the level of detail has been established by the EPA in QA/R-5 (EPA 2001; Reissued May 31,2006).

Site Assessment activities include environmental data operations performed as interim steps ofa larger group of operations. Such projects include work producing results that are used to evaluate and select options for interim decisions or to perform feasibility studies or preliminary assessments of unexplored areas for possible future work. For Site Assessment activities, a QAPP, as outlined below, will be prepared and included in FSPs.

1. Proj ect Management • Title and Approval Sheet • Table of Contents

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Distribution List Project/Task Organization Problem Definition/Background Project/Task Description Data Quality Objectives for Measurement Data Project Narrative Special Training Requirements/Certification Documentation and Records

Data Generation and Acquisition Sample Process Design (Experimental Design) Sampling Methods Sample Handling and Custody Analytical Methods Quality Control Instrument/Equipment Testing, Inspection, and Maintenance Instrument Calibration and Frequency Inspection/Acceptance Requirements for Supplies and Consumables Non-Direct Measurements Data Management

Assessment'Oversight Assessment and Response Actions Reports to Management

Data Validation and Usability Elements Data Review, Validation, and Verification Validation and Verification Methods Reconciliation with Data Quality Objectives

The QAPP will be prepared in a controlled document format, with provision for both a record of revision and a record of distribution. The QAPP will document the DQOs or acceptance criteria for projects, identifying the critical measurements to be performed, and discussing the QA activities to be conducted during the sampling, analytical, and validation phases ofa project. Project specific DQOs and acceptance criteria are included in the project-specific FSP.

8.3 FIELD SAMPLING PLAN

An FSP is developed for discrete sampling events in accordance with EPA guidance (EPA 1988). These plans are complementary to QAPPs, presenting similar information but differing in the planning perspective. For site assessment activities, project-specific information required in the generic QAPP is provided in the FSP.

The FSP includes the following information:

• Introduction • Site background: Site location and description, site operations and waste characteristics • Project description: Objectives and scope, anticipated data types and uses;

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Sampling program: Sampling methods, analytical and handling requirements, equipment decontamination, investigation-derived wastes, personnel health and safety; Project management: Organization and responsibility, schedule of tasks/milestones; QA procedures: QC checks, corrective action, performance and system audits, QA reports Project-specific QA requirements: QC sample quantities, DQOs, analytical specifications; Reporting requirements; and References.

8.4 ENVIRONMENTAL TECHNOLOGY DESIGN, CONSTRUCTION AND OPERATION QA PROJECT PLANS

This QAPP is the planning documentation for projects that require the design, construction, and operation of environmental technology projects. Design and construction planning involves the use of technical and engineering principles and practices to ensure that the removal meets or exceeds design criteria, plans, and specifications. Environmental technology involves both construction QC, (i.e., the planned system of inspections that are used to directly monitor and control the quality ofa construction project) and construction QA (i.e., the planned system of activities that provide assurance that the facility was constructed as specified).

The TL is responsible for preparing a QAPP for an environmental technology design, construction and operation project. The format and content of a QAPP for an environmental technology project incorporates the QA principles presented in the QMP and addresses EPA requirements for design and construction projects (EPA 2005a). A URS QAPP for design and construction contains the following elements:

Title page with provision for approval signatures; Introduction; Project description; Project organization and responsibilities; Quality assurance requirements; Design control; Supplier selection; Procurement control; Inspection activities and compliance monitoring; Control of measuring and test equipment; Evaluation and testing of items; Control of nonconforming items; Corrective action; Quality records; and Audits.

8.5 HEALTH AND SAFETY PLANS

HASPs are developed or adopted for all activities at a site and are consistent with the protocols described in the URS SMSs. The HASP is reviewed and approved by the URS Health and Safety Officer or a designee. The Health and Safety Officer has the authority to suspend or stop work with the concurrence ofthe EPA and PM

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upon detection and identification of an immediate adverse condition affecting the health and safety of personnel.

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Figure 8-1 The Data Quality Objectives Process

State the Problem

Identify the Decision

1 Identify Inputs to the Decision

1 Define the Study Boundaries

1 Develop a Decision Rule

1 Specify Limits on Uncertainty

Optimize the Design for Obtaining Data |

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Table 8-1 Quality Assurance Communications Requirements

Document

1

2

3

4

5

6

Quality Mgt Plan

QA Project Plan

Field Sampling Plan

Removal Quality Assurance Project

Plan

QA/QC Sampling Plan/Work Plan

Standard Operating Procedure

QA Annual Report and Work Plan

Perfonnance & System Audits Surveillance

Independent Technical Review

Responsible Initiator

QAO

QAO

Team Leader

Team Leader

Team Leader

PM

QAO

QAO

QAO

Team Leader

How Often Issued

Once and revisions thereafter

Once for each project and revisions

thereafter


thereafter


thereafter


thereafter

Once for URS project and revisions

thereafter

Annually

Once for each scheduled audit

Once for each review

Review Requirement

PM

Responsible EPA Official

PM


PM


PM, QAO

Responsible EPA Official •

PM, QAO


QAO


PM


PM

QAO

PM or TL

QAO

Follow-up Action (if any)

QAO

QAO

Team Leader

Team Leader

Team Leader

QAO

QAO

Team Leader

Team Leader

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9.0 IMPLEMENTATION OF WORK PROCESSES

The following sections describe the implementation procedures for quality management.

9.1 RESPONSIBILITY FOR IMPLEMENTATION

The PM in conjunction with the QAO is responsible for the implementation ofthe QMP, SOPs, and audits which are the fundamental components ofthe Quality System. The TL is responsible for the successful implementation ofthe site-specific plans and procedures.

Environmental data collection is implemented by qualified personnel according to approved project plans and procedures in a manner that ensures that the type and quality of environmental data required and expected are obtained. Deviations from approved plans and procedures require the concurrence of the PM (and the EPA responsible party, if significant) and are thoroughly documented. The impact and significance ofthe deviations on planned operations are determined and appropriate adjustments to such operations are made as needed. Changes to planning documents and operating guides and manuals are made and distributed to project personnel to replace previous documents.

9.2 MECHANISMS FOR IMPLEMENTATION

The QMP and QAPPs identify mechanisms that ensure that work is performed according to plans and commensurate with project DQOs. The TL is responsible for coordinating and implementing activities according to SOPs and the project-specific QAPPs. In order to meet the quality requirements of these documents, the TL ensures that:

• Only qualified and accepted services and items are used in the environmental data operations. • Inspections and acceptance testing of field sampling, measurement, and analytical instrumentation (or

other measurement systems) and equipment are performed. • Field equipment used for data acquisition are operated and calibrated in accordance with the

manufacturers' instructions and URS SOPs. • Periodic preventive and corrective maintenance of measurement and testing equipment is performed to

ensure availability and satisfactory performance ofthe equipment. • Handling, storage, cleaning, packaging, shipping, and preservation of field and laboratory samples are

performed according to URS SOPs to prevent damage, loss, deterioration, or contamination of the samples.

• Standard sample labels are attached to the sample container and provide sample inventory control information that is recorded on the chain-of-custody (C-O-C) form and that the C-O-C forms are tracked and documented.

• Data or information management, including transmittal, storage, validation, assessment, processing, and retrieval, is performed in accordance with the approved instructions, methods, and procedures. Data recorded in a structured digital fonnat is made available to EPA in a specified format and on appropriate magnetic media when requested.

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• Information sources used to obtain data include: EPA personnel and files; federal, state, and local agencies; published and unpublished documents; knowledgeable personnel and contacts; and direct measurement or observation.

• Sufficient documentation is maintained to allow an independent evaluation of the data including its source, validity, and quality and that information collected appears in field logbooks, letters, meeting notes, telephone conversation records, memoranda, reports, and data collection forms.

• Field data acquisition is based on recognized standards and methods. These methods are evaluated before and during application to verify accuracy, suitability, and repeatability.

9.2.1 Standard Operating Procedures

URS has identified, prepared and implemented SOPs that are used for information and data gathering activities. The SOPs are consistent with current regulations and guidelines and are clear and concise. The SOPs are complete and contain directions that can be followed in a stepwise manner. They are based on sound scientific technical and engineering principles.

URS personnel follow the SOPs unless specifically instructed otherwise. Each TL is responsible for ensuring that SOPs are available, before tasks are implemented, for any activity affecting quality of data. URS has prepared SOPs that cover:

• Equipment • Quality assurance • Technical SOPs • Analytical services • Health and Safety

SOP 2.1 "Standard Operating Procedure Preparation" establishes the outline, format and method to be used in preparing, reviewing, and approving SOPs. Revisions to an existing SOP follow the same procedures. SOPs may be written by any technical individual or group, but in all cases they are authorized by the PM and QAO. The QAO ensures that SOPs are incorporated into project plans, monitored and assessed for projects.

9.2.2 Quality Control Checks

QC samples are not collected and analyzed in all circumstances. The number and type of QC samples collected are determined by the type of data to be collected as identified during the DQO process. QC checks of both field sampling and laboratory sample analysis are used to assess and document data quality and to identily discrepancies in the measurement process that need correction. QC samples are used to determine the representativeness ofthe environmental samples, the precision of sample collection and handling procedures, the thoroughness ofthe field equipment decontamination procedures, and the accuracy of laboratory analysis.

In addition to field QC samples, the analytical laboratory uses a series of QC samples specified in each standard analytical method to assess laboratory performance. The types of laboratory QC samples are method blank, laboratory control standard, duplicate, matrix spike, and matrix spike duplicate. Analyses of laboratory QC samples are performed for samples of similar matrix type and concentration and for each sample batch. QC samples collected to assess field sample collection procedures are as follows.

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Field Blanks are used to indicate the presence of extemal contaminants that may have been introduced into the samples during collection.

Trip Blanks are used to assess contamination introduced into the sample containers by volatile organics through diffusion during sample transport and storage.

Equipment Blanks (equipment decontamination rinsates) are used to assess the adequacy of practices to prevent cross-contamination between sampling locations and samples.

Field Replicates (or duplicates) are collected at selected locations to provide estimates ofthe total sampling and analytical precision. At least one replicate sample is analyzed from each group of 20 samples ofa similar matrix type and concentration.

Standard Reference Samples are used to assess the accuracy ofthe analytical methods specified and to assess the performance ofthe laboratory sample analysis. These samples are prepared with a known composition and analyte concentration by an independent laboratory and submitted to the analytical laboratory as unknown samples.

9.2.3 Data Validation

The purpose ofthe validation process is to eliminate unacceptable analytical data and to designate a data qualifier for any data quality limitation discovered. In some instances, the analytical data may be used only for approximation purposes. Data validation criteria are discussed below for both field and laboratory data.

Field Data Validation is conducted to eliminate data that are not collected or documented in accordance with specified protocols outiined in the QAPP and FSP. In some instances, the field data are used only for approximation purposes and do not require validation. Validation of field data is performed on two separate levels. First, field data are validated at the time of collection by following the QC checks outiined in the QAPP and FSP. Second, the TL reviews the field data documentation to identify discrepancies or unclear entries. Field data documentation are validated against the following criteria:

Sample location and adherence to the plan; Field instrumentation calibration; Sample collection protocol; Sample volume; Sample preservation; Blanks collected and submitted with each respective sample set; Duplicates collected and submitted with each respective sample set; Sample documentation protocols; C-O-C protocol; and Sample handling and shipment.

The QAO or designee conducts Analytical Data Validation. The quality control data requirements and

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deliverables are specified in the QAPP. The data report is then validated in accordance with the criteria contained in EPA guidance documents modified for the analytical method used. Data validation reports are filed with the data and describe the usability ofthe data for further technical interpretations. Analytical data are validated against the following criteria:

Holding times; Instrument performance checks; Initial and continuing calibration; Blank analyses; Laboratory QC compounds and standards; Field duplicates analysis; Intemal standard performance; Compound identification and compound quantitation; Reported detection limits; System performance; and Overall assessment of data.

9.2.4 Systems and Performance Audits

Systems and performance audits are conducted to confirm adherence to QA plans and to document deficiencies in the QA and QC systems. Systems audits ensure that measurement systems generate qiiality data, that management systems sufficiently implement the QA System, and that subcontractors perform work within established QA guidelines. Performance audits are conducted for each major environmental monitoring and data collection activity soon after the measurement system is generating data and on a regularly scheduled basis thereafter, as defined in the QAPP. Refer also to Section 10 ofthis QMP.

9.2.5 Inspection Documentation

SOPs for Construction Quality Assurance Project Plans (CQAPPs) for construction oversight define the activities that fulfill the project requirements. Inspectors record descriptive remarks on data sheets and checklists signed by them verifying that the inspection activities have been accomplished.

Observations and field tests are recorded on inspection data sheets. Recorded observations take the form of notes, charts, sketches, photographs, or any combination of these. Checklists ensure that no pertinent factors of a specific observation are overlooked. At a minimum, the inspection data sheets are prepared daily and include the following information:

• Personnel involved in the inspection activity; • Description or titie ofthe inspection activity; • Location ofthe inspection activity or location from which the sample increment was obtained; • Date and data on weather conditions; • Report on any meetings held and their results; • Unit processes and locations of construction underway; • Equipment being used in each unit process; • Identificationof subcontractors doing the work;

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Descriptions of areas or units ofwork being inspected and documented. Type of inspection activity and inspection procedure used; Recorded observation or test data, with necessary calculations; Results ofthe inspection activity and comparison with specification requirements; Problems identified and corrective measures taken to resolve the problems.

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10.0 ASSESSMENT AND RESPONSE

Assessments are utilized to increase the user's understanding ofthe activity being assessed and to provide a basis for improving that activity. URS staff or independent subcontractors may conduct assessments. Assessments are planned and documented based on program or project requirements. Both self-assessments and independent assessments utilize one or more assessment tools such as reviews, surveillance, formal audits and technical documentation reviews. Assessment responsibilities, planning, tools and responses are summarized below and are fully presented in the URS QA SOPs.

10.1 RESPONSIBILITY FOR ASSESSMENTS

QA/R-2 requires that assessments be conducted by personnel who have sufficient authority, access to work areas, and organizational freedom to:

• Identify quality problems; • Identify and cite practices that may be shared with others to improve the quality of their operations

and products; • Propose recommendations for resolving quality problems; • Independently confirm implementation and effectiveness of solutions; • Provide documented assurance to line management that, when problems are identified, further work

performed is monitored carefully until the problems are suitably resolved; and • Suspend or stop work with the concurrence of the PM, QAO, and EPA, upon detection and

identification of an immediate adverse condition affecting the quality of results.

This authority and freedom is provided by an independent reporting pathway through the QAO who is responsible to the URS corporate QA Director and PIC as opposed to the PM.

10.2 IMPLEMENTATION OF ASSESSMENTS

Approaches used for the assessments vary with the objectives ofthe assessment and the status ofthe project, but are of two basic types:

• Management and technical self-assessment: the qualitative assessment ofa management or technical system by those immediately responsible for overseeing and/or performing the work.

• Management and technical independent assessment: the qualitative assessment of management or technical system by someone other than the group performing the work.

Assessments are planned by the URS management staff (PM for program-level activities; PM, or TL for project level activities) in conjunction with the QAO. Field and construction activity supervisors may plan assessments of specific activities in their areas of expertise. The planning process results in a written statement of work or procedure that defines the scope ofthe assessment and the information needed. The planning process includes:

• Reviewing system and project-specific requirements identified within project plans; • Defining acceptance criteria;

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• Developing an outline or check list of critical technical functions and procedural requirements; • Defining the responsibility and authority ofthe person(s) conducting the assessment; and • Assuring that the personnel scheduled to conduct the assessment have adequate training and

experience. The capability of personnel conducting assessments is detennined by review of their training, certification, and experience with the program, project, or system being assessed. Assessor qualifications must be equivalent to or higher than the individual whose activity is to be assessed and must have no real or perceived conflict of interest.

The frequency and responsibility for implementation of management assessments is determined by the PM in consultation with the QAO and is based on the level ofthe activity being assessed. The schedule for management assessments is:

• Annual, independent assessment of the prevailing quality management structure, policies and practices;

• Annual self-assessment of the management and Quality System activities as they impact overall quality ofthe service and products delivered (e.g., QA Annual Report and Work Plan);

Technical assessments are scheduled by the PM in consultation with the TL but may be requested by the PM. The schedule for technical assessments is based on the status, risk, and activities in progress and is documented in project-specific plans. In addition to scheduled assessments, technical personnel conduct routine, informal assessments of their work and may request a formal assessment to clarify or document unusual or complex activities.

Assessment findings, recommendations, and corrective actions are documented in a report to the PM, QAO (and TL, when appropriate). This report is prepared in accordance with Element 17 ofthe URS Quality Assurance Manual and includes:

Names ofthe parties responsible for the assessment; A copy of guidelines developed for the assessment; Brief description ofthe activity assessed; Description ofany quality problems; Recommendations for resolving any quality problems; and Suggestions for sharing and noteworthy practices.

10.3 MECHANISMS FOR ASSESSMENT

The tools for assessment include:

Management systems reviews; Quality System reviews; Audits and surveillances; Independent technical reviews and peer reviews; Readiness reviews; Data reduction assessment; and

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Data quality assessments.

10.3.1 Management System Review

The URS management system framework and infrastructure, as it impacts the overall quality ofthe service and products delivered is reviewed to ensure:

• Effectiveness ofthe system of management controls that are established to achieve and ensure quality;

• Adequacy of resources and personnel provided to achieve and ensure quality in activities;

• The effectiveness of training and audits;

• Applicability of DQOs and software.

The results of management system reviews, as well as accomplishments and significant quality problems are summarized and transmitted to EPA.

10.3.2 Quality System Review

The Quality System is reviewed to assess the effectiveness ofthe QMP, QAPPS and SOPs, to identify recurring QA problems and to implement corrective actions. Formal annual review ofthe Quality System is conducted by the QAO. Revisions are prepared by the QAO, with the concurrence of the PM, and issued as a controlled revision to the QMP. Major revisions, that may present significant programmatic impact, are submitted to EPA for approval prior to implementation and necessitate reissuance ofa revised QMP.

A written QA report is prepared annually by the QAO containing the results ofthe QA System review. The following topics are addressed within the report:

Implementation status, or changes to, the QMP, QAPPs/FSPs and SOPs; Significant QA accomplishments, recommendations, and problems; Instrument, equipment, or procedural problems that affect QA; Measures of data quality and status for meeting DQOs; Results of performance and system audits and status of corrective actions; Status of QA requirements for subcontracts; Summary of QA training; and Objectives from the previous report that were not achieved; and Work planned for the next reporting period.

10.3.3 Audits and Surveillance

Systems and performance audits and surveillance are conducted as the principal means to determine compliance with the QMP, the site assessment QAPP, site-specific FSPs and QAPPs, and DQOs identified within. Audits and surveillance are used to formally review systems and individual projects, during their course and across levels of management. The QAO has the primary responsibility for conducting audits and surveillance, portions of which may be delegated to an auditing team comprised of senior technical specialists.

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Copies of the audit reports are maintained in the QA administrative files and in the project files and are transmitted to the EPA when requested by the EPA. Technical specialists must be familiar with the technical and procedural requirements of both field and laboratory operations, and the associated QA plans. In addition, auditors can not be directly involved with the actual tasks themselves, so as not to infroduce bias in the auditing process. Several factors are taken into consideration for determining the scope and frequency for audits and surveillance as follows:

Complexity ofthe task order; Applicable regulations; Program guidance; Project or task scope and duration; Data quality objectives; Deliverable requirements; Subcontractor participation; Emergency conditions; Criticality of data collection; and Potential for or frequency of nonconformances.

Surveillance is less formal than audits, but generally they follow the same procedures as an audit. Line management or the QAO may initiate surveillance when a need for such is determined.

An audit or surveillance may be initiated prior to the award ofa subcontract to determine the capability ofa potential subcontractor; to assess a newly-instituted QA program; when reorganization or major revision has been made to the QAPP or FSPs; to confirm development of SOPs or other controlling documents; when scheduled audits are established by the program or project planning documents; at any time a nonconformance is suspected; or to verify that corrective actions for nonconformance have been implemented.

Procedure 6 ofthe URS Quality Management System describing auditing procedures and Procedure 7 ofthe URS Quality Management System describes corrective and preventative actions. Audit steps include provisions for scope, schedule, checklist, findings, nonconformance reports, corrective action, follow-up review ofthe corrective action, resolution of conflicts, and stop work notices.

The QAO submits notice ofany laboratory or field system audits prior to their occurrence and in a timely manner to EPA. Audits are scheduled such that an EPA representative may attend and observe the audit. Surveillance results and subsequent resolution of issues are documented within memoranda and filed with the program or project documents. Four types of audits are as follows:

Performance Audits are used to determine the status and effectiveness of both field and laboratory measurement systems and a quantitative measure ofthe quality of data generated.

Data Quality Audits are conducted to assess the effectiveness and documentation of the data collection and generation processes and to verify that the generated data are of known and documented quality.

Technical System Audits are used to confirm the adequacy ofthe data collection (field operation) and data generation (laboratory operation) systems. The on-site audits are conducted to determine whether the QAPP and

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SOPs are being properly implemented.

Management System Audits are used to formally review the entire URS program management to determine whether QA is properly implemented for key components of the program. Management system audits also evaluate the ability ofthe project management to meet programmatic requirements or to meet specified data and information collection DQOs.

10.3.4 Independent Technical Review and Peer Review

An independent technical review is a documented critical review ofwork ofa substantive nature or identified as a deliverable. A peer review is a documented critical review ofwork characterized by the existence of potential uncertainty. Independent technical reviews are conducted in a variety of areas throughout the URS contract, across lines of management, and involving appropriate technical disciplines. These reviews are conducted by experienced and qualified personnel to ensure the quality and integrity of tasks and products by allowing the work and/or deliverable to undergo objective, critical scrutiny. The QAO and PM are responsible for ensuring that reviewers are independent from actual work or decision-making on the tasks or activities being reviewed, and possess technical qualifications sufficient for conducting the in-depth review. Section 3.4 and 3.51 outline the procedures for Detail Checking and Independent Technical Review, respectively. A written record ofthe review and resolution ofthe review findings is incorporated into the project files.

The independent technical review and peer review process is used as a management tool to assess the following:

Soundness of a technical approach or result; Application of complicated problem-solving techniques; Changes in the scope of a project; Transition between phases ofa sampling event; Problems identified in a project or report; Major decisions made at the planning stage or during the course of a project; Potential for erroneous assumptions, data, calculations, methods, or conclusions; Basis of design criteria and calculations; Construction cost estimates; and Constructibility of design.

Independent technical reviews and peer reviews are conducted for (but are not limited to):

Work Plans; FSPs; QAPPs; Technical approaches; Technical memoranda; Studies and investigations; Reports of site inspections, chemical safety audits, contingency plans; Draft and final reports; Design criteria; Cost estimates;

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• Plans and specifications; • SOPs; and • Subcontract scopes of work.

10.3.5 Readiness Review

A readiness review is a systematic, documented review of the readiness for the start up or continued use of a facility, process, or activity. Readiness reviews are typically conducted before proceeding beyond project milestones and prior to initiation ofa major phase ofwork. Readiness reviews are performed by the PM, when needed during key successive phases of a project.

10.3.6 Data Reduction Assessment

The project QAPP outlines the procedures for verifying the accuracy ofthe data reduction process. Each project QAPP describes the methods used to ensure that data transfer is error-free (or has an admissible error rate), that no information is lost in the transfer process, and that the output is completely recoverable from the input. In order to reduce the risks associated with data transfer, this process is kept to a minimum. Data are reduced either manually on calculation sheets or by computer on formatted printouts. The following responsibilities are delegated in the data reduction process:

• Technical personnel document and review their own work and are accountable for its correctness;

• Major calculations receive both a method and an arithmetic check by an independent checker. The checker is accountable for the correctness ofthe checking process; ^

• An Independent Technical Review is conducted to ensure the consistency and defensibility of the concepts, methods, assumptions, calculations, etc., as scheduled by the TL; and

• The TL is responsible for ensuring that data reduction is performed in a manner that produces quality data through review and approval of calculations.

Hand Calculations must be legibly recorded on calculation sheets and in logical progression with sufficient descriptions. Major calculations are checked by an engineer or scientist of professional level equal to or higher than that of the originator. After completing the check, the checker signs and dates the calculation sheet immediately below the originator. Both the originator and checker are responsible for the correctness of calculations. A calculation sheet contains the following, at a minimum:

Project titie and brief description ofthe task; Task number and date performed; Signature of person who performed the calculation; Basis for calculation; Assumptions made or inherent in the calculation; Complete reference for each source of input data; Methods used for calculations; and Results of calculations, clearly annotated.

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Computer Analysis includes the use of models, programs, data management systems, etc. For published software with existing documentation, test case runs are periodically performed to verify that the software is performing correctly. Both systematic and random error analysis are investigated and appropriate corrective action measures taken.

Documentation for in-house developed models and programs is reviewed by the PM prior to use. This documentation is prepared in accordance with computer program verification procedures and contains at a minimum:

• Description of methodology and engineering basis; • Major mathematical operations; • Flow chart presenting the organization ofthe model or program; and • Test case(s), sufficiently comprehensive to test model or program operations.

QC procedures for checking models (or programs) involve reviewing the documentation, running the test case, and manually checking selected mathematical operations. Each computer run has a unique number, date, and time associated with it appearing on the printout. QC measures are documented as referenced in applicable procedures.

10.3.7 Data Quality Assessment

Data Quality Assessments are prepared to document the overall quality of data collected in terms of the established DQOs. The data assessment parameters calculated from the results ofthe field measurements and laboratory analyses are reviewed to ensure that data used in subsequent evaluations are scientifically valid, of known and documented quality, and, where appropriate, legally defensible. In addition, the performance ofthe overall measurement system is evaluated in terms ofthe completeness ofthe project plans, effectiveness of field measurement and data collection procedures, and relevance of laboratory analytical methods used to generate data as planned. Finally, the goal ofthe data quality assessment is to present the findings in terms of data usability. In summary, the data quality assessment process:

Assesses the quality of data values generated or measured against the established DQOs for parameters such as precision, accuracy, completeness, representatives, and comparability, and against acceptance criteria established for these parameters; and

Achieves an acceptable level of confidence in the decisions that are to be made from measurements and data by controlling the degree of total error permitted in the data through QC checks. Data that fail the QC checks or do not fall within the acceptance criteria established are rejected from further use or qualified for limited use.

The major components ofa data quality assessment are presented below and show the logical progression ofthe assessment leading to determination of data usability:

• Summary of the individual data validation reports for sample delivery groups by analytical method. Systematic problems, data generation trends, general conditions of the data, and reasons for data qualification are presented;

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• Description ofthe procedures used to further qualify data caused by dilution, reanalysis, and duplicate analysis of samples. Examples ofthe decision logic are provided to illustrate the methods by which qualifiers are applied;

• Evaluation of QC samples such as, field blanks, trip blanks, equipment rinsates, field replicates and laboratory control samples to assess the quality ofthe field activities and laboratory procedures;

• Assessment of the quality of data measured and generated in terms of accuracy, precision, and completeness through the examination of laboratory and field control samples in relation to objectives established and correct application of statistical methods.

• Summary ofthe usability of data, based upon the assessment of data conducted during the previous four steps. Sample results for each analytical method are qualified as acceptable, rejected, estimated, biased high, or biased low.

10.4 RESPONSE TO ASSESSMENTS

The PM and TLs review and respond to assessment findings in a timely manner in accordance with URS QA SOPs. This response will depend upon the potential impact and/or time-critical nature ofthe quality problem. It is the responsibility ofthe QAO to confirm the implementation and effectiveness ofthe response action.

• Time-Critical, Significant Impact. Example: A field audit finds that a subcontractor is using an inappropriate analytical procedure. The assessor notifies the TL and QAO from the field, discusses altematives; attempts to take immediate corrective action; and, if necessary, stops work with concurrence oftheTL, PM, andEPA.

• Time-Critical, Minor Impact. Example: An audit finds that sample labels are messy but information is useable. The assessor notifies the TL and documents the finding.

• Not Time-Critical, Possible Major Impact. Example: A management assessment determines that a procedure for sampling is in error. The assessor incorporates a description and recommendation into a report to the PM and QAO. The PM establishes a schedule for corrective action, designates a responsible person, and determines what documentation ofthe corrective action is required; the QAO follows up to confirm that the corrective action has been implemented.

• Not Time-Critical, Minor Impact. Example: A management assessment determines that the numbering system for the procedures is obsolete. The assessor describes the problem; discusses a solution with the responsible person; and reports to the PM that the issue has been resolved; the QAO follows up to confirm that the corrective action has been implemented.

Further discussion ofresponse to assessments including how, when, and by whom corrective actions are taken is continued in Section 11.

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11.0 QUALITY IMPROVEMENT

The URS Quality System is designed and continually assessed to minimize problems that affect the quality ofthe work being undertaken. The ongoing assessment process described in Section 10 includes reviews, audits, surveillances, independent technical reviews and other assessment tools, and reveals both the strengths and weaknesses ofthe URS Quality System. In addition, EPA evaluations provide important information regarding the practical application ofthe Quality System as it functions to provide a framework for technical activities on various projects. Improvements to the Quality System are made based on careful review of assessments and evaluations followed by revisions to plans and procedures and subsequent training. It is the responsibility of URS management to provide active leadership and participation in continuous quality improvement to ensure that proper focus is given, adequate resources are provided, and difficult issues are resolved.

The PM receives the QA audits, reviews, surveillance reports, and training records, as well as direct input from EPA program and project managers and URS or subcontractor employees. The PM is responsible for identifying, planning, implementing and evaluating the effectiveness of quality improvement activities. It is the responsibility of the PM to focus on management quality improvements, while the PM focuses on technical quality improvements.

11.1 NON-CONFORMANCE AND CORRECTIVE ACTION

The URS program and project plans, supplementary procedures and training establish the baseline for assessing the Quality System. Management and technical staff follow these plans and procedures during the course ofany URS activity, however, on occasion, non-conformances do occur. Each nonconformance is documented by the URS or subcontractor employee observing the nonconformance. Examples of nonconforming work include:

• Items that do not meet the contractual requirements by a subcontractor supplier; • Errors made in following work instruction or improper work instruction; • Unforeseen or unplanned circumstances that result in services that do not meet

quality/contractual/technical requirements; • Unapproved or unwarranted deviations from established procedures; • Errors in craftsmanship or trade skills; • Non-validated or verified computer programs; • Sample Chain-of-Custody missing or deficient; and • Data falling outside established DQO criteria.

Results of QA reviews and audits typically identify the requirement for a corrective action. The QAO is responsible for reviewing audit and nonconformance reports to determine areas of poor quality or failure to adhere to established procedures. Nonconformances are formally reported by the QAO to the TL. The TL is responsible for evaluating reported nonconformances, determining the root cause, conferring with the QAO on the steps to be taken for cortection, and executing the corrective action as developed and scheduled. Corrective action measures are selected to prevent or reduce the likelihood of future occurrences and address the root causes to the extent identifiable. Selected measures are appropriate to the seriousness ofthe nonconformance and are realistic in terms ofthe resources required for implementation.

In summary, corrective action involves the following steps:

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• Discovery of a nonconformance; • Identification ofthe responsible party; • Determination of root causes; • Plan and schedule of corrective/preventive action; • Review ofthe corrective action taken; and • Confirmation that the desired results were produced.

Procedure 7 ofthe URS Quality Management System describes the requirements for reporting evaluation and correction of nonconformances that are discovered during the course of an audit or by staff members during the course of project work.

Upon completion ofthe corrective action, the QAO evaluates the adequacy and completeness ofthe action taken. If the action is found to be inadequate, the QAO and TL confer to resolve the problem and determine any further actions. The TL schedules implementation ofany further action. The QAO will issue a suspend or stop work notice with the concurrence ofthe PM and EPA in cases where significant problems continue to occur or a critical situation requires work to prevent further discrepancies, loss of data, or other problems. When the corrective action is found to be adequate, the QAO notifies the TL ofthe closeout of non-conformance.

The QAO maintains a log of nonconformances in order to track their disposition until correction and for trend analysis as necessary. Documentation associated with a nonconformance is entered into the project files and QA administrative files.

11.2 PROACTIVE QUALITY IMPROVEMENT

In addition to the assessment/corrective action approach to quality improvement, URS management and staff are encouraged to present their ideas for quality improvement at any time during the course of their program or project activities. These problems and suggestions are presented and discussed in the context ofthe overall purpose ofthe URS contract, at weekly meetings or directly with the QAO, PM or TL. Improvements that do not require revisions in program or project plans are documented in a memo and distributed to staff and, when necessary as determined by the QAO or PM, training sessions are held. Improvements that require revisions to program or project plans require approval ofthe PM and the EPA. These quality improvements are presented formally in a letter or document revisions and are distributed to potential users.

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12.0 TERMS AND DEFINITIONS

The following list of terms and definitions is provided for use with this QMP. Many ofthe terms are defined as used by EPA in other documents.

Activity - an -inclusive term describing a specific set of operations or related tasks to be performed, either serially or in parallel (e.g., research and development, field sampling, analytical operations, equipment fabrication), that in total result in a product or service.

Assessment - the evaluation process used to measure the performance or effectiveness of a system and its elements. In this Standard, assessment is an -inclusive term used to denote any of the following: audit, performance evaluation, management systems review, peer review, inspection, or surveillance.

Audit - a planned and documented investigative evaluation of an item or process to determine its adequacy and effectiveness as well as compliance with established procedures, instructions, drawings, QAPPs, and/or other applicable documents.

Bias - a systematic displacement of the observations in a statistical sample from the true or accepted value, or a systematic and consistent error in test results.

Calibration - comparison ofa measurement standard, instrument or item with a standard or instrument of higher accuracy to detect and quantify inaccuracies and to report or eliminate those inaccuracies by adjustments.

Chain of Custody (C-O-C) - an unbroken trail of accountability that ensures the physical security of samples, data and records.

Characteristic - any property or attribute ofa datum, item, process, or service that is distinct, describable, and/or measurable.

Comparability - a measure ofthe confidence with which one data set can be compared to another.

Completeness - a measure of the amount of valid data obtained from a measurement system compared to the amount that was expected to be obtained under correct, normal conditions.

Computer Program - a sequence of instructions suitable for processing by a computer. Processing may include the use of an assembler, a compiler, an interpreter, or a translator to prepare the program for execution. A computer program may be stored on magnetic media, and be referred to as "software," or may be stored permanently on computer chips, and be referred to as "firmware." Computer programs covered by this Standard are those used for design analysis, data acquisition, data reduction, data storage (data bases), operation or control, and data base or document control registers when used as the controlled source of quality information.

Confidentiality Procedure - a procedure used to protect confidential business information (including proprietary data and personnel records) from unauthorized access.

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Configuration - the functional, physical and procedural characteristics of an item, experiment or document.

Conformance - an affirmative indication or judgment that a product or service has met the requirements ofthe relevant specifications, contract or regulation; also the state of meeting the requirements.

Consensus Standard - a standard established by a group representing a cross section ofa particular industry or trade, or a part thereof

Contractor - any organization or individual that contracts to fumish services or items or perform work.

Corrective Action - measures taken to rectify conditions adverse to quality and, where necessary, to preclude their recurrence.

Customer - any individual or organization for whom items or services are fumished or work performed in response to defined requirements and expectations. See also Participant and User.

Data Quality Objectives (DQOs) - established quantitative measurements (with associated precision and bias or acceptable uncertainty) that must be obtained from the environmental data operations in order to demonstrate that the desired and expected result has been achieved. Such measurements are defined and established using the DQO Planning Process.

Data Quality Objectives Planning Process - a systematic planning tool based on decision analysis and operations research methodology to identify and define the type, quality, and quantity of data needed and expected from environmental data operations in order to satisfy a specified use. The process encompasses strong dependence on user participation and on the use of statistics. The key elements ofthe process include:

Understanding the user's problem or concerns that require resolution; Identifying the specific result that will fully satisfy the problem or concems; Defining the data and the performance measures necessary to demonstrate the resolution ofthe problem or concems;

• Establishing error probabilities for making incorrect conclusions; • Specifying the criteria for the measurements that will yield the expected results within acceptable

error probabilities for the intended use ofthe results; and • Optimizing the survey (or experimental) design for resource effectiveness.

Data Usability - the process of ensuring or determining whether the quality of the data produced meets the intended use ofthe data.

Deficiency - an unauthorized deviation from acceptable procedures or practices, or a defect in an item.

Design - specifications, drawings, design criteria and performance requirements. Also the result of deliberate planning, analysis, mathematical manipulations, and design processes.

Design Change - any revision or alteration ofthe technical requirements defined by approved and issued design output documents and approved and issued changes thereto.

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Date: 11/9/09 Page 46 of 53

Design Review - a documented evaluation by a team, including personnel such as the responsible designers, the customer for the work or product being designed, and a QA representative, but other than the original designers, to determine if a proposed design will meet the established design criteria and perform as expected when implemented.

Document - any written or pictorial infonnation describing, defining, specifying, reporting or certifying activities, requirements, procedures or results.

Engineered Environmental Systems - an -inclusive term used to describe pollution control devices and systems, waste treatment processes and storage facilities, and site remediation technologies and their components that may be utilized to remove pollutants or contaminants from the environment. Examples include wet scrubbers (air), soil washing (soil), granulated activated carbon unit (water), and filtration (air, water). Usually this term will apply to hardware-based systems; however, it will also apply to methods or techniques used for pollutant reduction or containment of contamination to prevent further movement ofthe contaminants, such as capping, solidification or vitrification, and biological treatment.

Environmental Conditions - the description ofa physical medium (e.g., air, water, soil, sediment) or biological system expressed in terms of its physical, chemical, radiological, or biological characteristics.

Environmental Data - any measurements or information that describe environmental processes or conditions, or the performance of environmental systems.

Environmental Data Operations - work performed to obtain, use, or report information pertaining to environmental processes and conditions.

Environmental Monitoring - the process of measuring or collecting environmental data.

Environmental Processes - manufactured or natural processes that produce discharges to or that impact the ambient environment.

Environmental Programs - an -inclusive term pertaining to any work or activities involving the environment, including but not limited to: characterization of environmental processes and conditions; environmental monitoring; environmental research and development; the design, construction, and operation of environmental technologies; and laboratory operations on environmental samples.

Environmental Technology - an -inclusive term used to describe pollution control devices and systems, waste treatment processes and storage facilities, and site remediation technologies and their components that may be utilized to remove pollutants or contaminants from or prevent them from entering the environment. Examples include wet scrubbers (air), soil washing (soil), granulated activated carbon unit (water), and filtration (air, water). Usually, this term will apply to hardware-based systems; however, it will also apply to methods or techniques used for pollution prevention, pollutant reduction, or containment of contamination to prevent further movement ofthe contaminants, such as capping, solidification or vitrification and biological treatment.

003010

URS ^ Quality Management Plan Revision; 2

Date; 11/9/09 Page 47 of 53

Evidentiary Records - records identified as part of litigation and subject to restricted access, custody, use and disposal.

Expedited Change - an abbreviated method of revising a document at the work location where the document is used when the normal change process would cause unnecessary or intolerable delay in the work.

Financial Assistance - the process by which funds are provided by one organization (usually govemment) to another organization for the purpose of performing work or fumishing services or items. Financial assistance mechanisms include grants, cooperative agreements, and govemment interagency agreements.

Finding - an assessment conclusion that identifies a condition having a significant effect on an item or activity. An assessment finding may be positive or negative, and is normally accompanied by specified examples ofthe observed condition.

Graded Approach - the process of basing the level of application of managerial controls applied to an item or work according to intended use ofthe results and the degree of confidence needed in the quality ofthe results. (See Data Quality Objectives Planning Process.)

Guideline - a suggested practice that is non-mandatory in programs intended to comply with a standard.

Hazardous Waste - any waste material that satisfies the definition of "hazardous waste" as given in 40 CFR Part 261, "Identification and Listing of Hazardous Waste."

Independent Assessment - an assessment performed by a qualified individual, group, or organization that is not a part ofthe organization directly performing and accountable for the work being assessed.

Inspection - examination or measurement of an item or activity to verify conformance to specific requirements.

Item - an -inclusive term used in place ofthe following: appurtenance, facility, sample, assembly, component, equipment, material, module, part, product, structure, subassembly, subsystem, system, unit, documented concepts, or data.

Management - those individuals directly responsible and accountable for planning, implementing, and assessing work.

Management System - a structured non-technical system describing the policies, objectives, principles, organizational authority, responsibilities, accountability, and implementation plan of an organization for conducting work and producing items and services.

Management Systems Review (MSR) - the qualitative assessment of a data collection operation and/or organization(s) to establish whether the prevailing quality management structure, policies, practices, and procedures are adequate for ensuring that the type and quality of data needed are obtained.

May - denotes permission but not a requirement.

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Date; 11/9/09 Page 48 of 53

Measurement and Testing Equipment - tools, gauges, instruments, sampling devices or systems used to calibrate, measure, test or inspect in order to control or acquire data to verify conformance to specified requirements.^

Method - a body of procedures and techniques for performing an activity (e.g., sampling, chemical analysis, quantification) systematically presented in the order in which they are to be executed.

Mixed Waste - hazardous waste material as defined by 40 CFR 261 (RCRA) and mixed with radioactive waste subject to the requirements ofthe Atomic Energy Act.

Must - denotes a requirement that has to be met.

Nonconformance - a deficiency in characteristics, documentation or procedure that renders the quality of an item or activity unacceptable or indeterminate.

Objective Evidence - any documented statement of fact, other information or record, either quantitative or qualitative, pertaining to the quality of an item or activity, based on observations, measurements or tests which can be verified.

Observation - an assessment conclusion that identifies a condition (either positive or negative), which does not represent a significant impact on an item or activity. An observation may identify a condition that does not yet cause a degradation of quality.

Participant - when used in the context of environmental programs, an organization, group or individual that takes part in the planning and design process and provides special knowledge or skills to enable the planning and design process to meet its objective.

Peer Review - a documented critical review ofwork generally beyond the state ofthe art or characterized by the existence of potential uncertainty. The peer review is conducted by qualified individuals (or organization) who are independent of those who performed the work, but are collectively equivalent in technical expertise (i.e., peers) to those who performed the original work. The peer review is conducted to ensure that activities are technically adequate, competently performed, properly documented, and satisfy established technical and quality requirements. The peer review is an in-depth assessment ofthe assumptions, calculations, extrapolations, altemate interpretations, methodology, acceptance criteria, and conclusions pertaining to specific work and of the documentation that supports them. Peer reviews provide an evaluation ofa subject where quantitative methods of analysis or measures of success are unavailable or undefined, such as in research and development.

Performance Evaluation (PE) - a type of audit in which the quantitative data generated in a measurement system are obtained independently and compared with routinely obtained data to evaluate the proficiency of an analyst or laboratory.

Pollution Prevention (P2) - an organized, comprehensive effort to systematically reduce or eliminate pollutants or contaminants prior to their generation or their release or discharge to the environment.

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Date; 11/9/09 Page 49 of 53

Precision - a measure of mutual agreement among individual measurements ofthe same property, usually under prescribed similar conditions, expressed generally in terms ofthe standard deviation.

Procedure - a documented set of steps or actions that systematically specifies or describes how an activity is to be performed.

Process - an orderly system of actions that is intended to achieve a desired end or result. Examples of processes include analysis, design, data collection, operation, fabrication, and calculation.

Project - an organized set of activities within a program.

Qualified Data - any data that have been modified or adjusted as part of statistical or mathematical evaluation, data validation, or data verification operations.

Qualified Services - an indication that suppliers providing services have been evaluated and determined to meet the technical and quality requirements of the customer, as provided by approved procurement documents and demonstrated by the supplier to the customer's satisfaction.

Quality - the totality of features and characteristics ofa process or service that bears on its ability to meet the stated or implied needs and expectations ofthe user.

Quality Assurance (QA) - an integrated system of managementactivities involving planning, implementation, assessment, reporting, and quality improvement to ensure that a process, item, or service is ofthe type and quality needed and expected by the customer.

Quality Assurance Program Description/Plan - see Quality Management Plan.

Quality Assurance Project Plan (QAPP) - a formal document describing in comprehensive detail the necessary QA, QC, and other technical activities that must be implemented to ensure that the results ofthe work performed will satisfy the stated performance criteria.

Quality Control (QC) - the overall system of technical activities that measures the attributes and perfonnance of a process, item, or service against defined standards to verify that they meet the stated requirements established by the customer.

Quality Improvement - a management program for improving the quality of operations. Such management programs generally entail a formal mechanism for encouraging worker recommendations with timely management evaluation and feedback or implementation.

Quality Indicators - measurable attributes of the attainment of the necessary quality for a particular environmental decision. Indicators of quality include precision, bias, completeness, representativeness, reproducibility, comparability, and statistical confidence.

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Date; 11/9/09 Page 50 of 53

Quality Management - that aspect ofthe overall management system ofthe organization that determines and implements the quality poHcy. Quality management includes strategic planning, allocation of resources, and other systematic activities (e.g., planning, implementation, and assessment) pertaining to the quality system.

Quality Management Plan (QMP) - a formal document that describes the quality system in terms of the organizational structure, functional responsibilities of management and staff, lines of authority, and required interfaces for those planning, implementing, and assessing activities conducted.

Quality System - a stmctured and documented management system describing the policies, objectives, principles, organizational authority, responsibilities, accountability, and implementation plan of an organization for ensuring quality in its work processes, products (items), and services. The quality system provides the framework for planning, implementing, and assessing work performed by the organization and for carrying out required QA and QC.

Radioactive Waste - waste material containing radionuclides, or contaminated by radionuclides, subject to requirements ofthe Atomic Energy Act.

Readiness Review - a systematic, documented review ofthe readiness for the Start up or continued use ofa facility, process, or activity. Readiness reviews are typically conducted before proceeding beyond project milestones and prior to initiation of a major phase ofwork.

Record (Quality Assurance) - a document that fumishes evidence ofthe quality of items or activities and that has been verified and authenticated as technically complete and correct. Records may include photographs, drawings, magnetic tape, and other data recording media.

Remediation - the process of reducing the concentration ofa contaminant (or contaminants) in air, water, or soil media to a level that poses an acceptable risk to human health.

Representativeness - a measure ofthe degree to which data accurately and precisely represent a characteristic of a population, parameter variations at a sampling point, a process condition or an environmental condition.

Reproducibility - the precision, usually expressed as a standard deviation, which measures the variability among the results of measurements ofthe same sample at different laboratories.

Research (Applied) - a process, the objective of which is to gain knowledge or understanding necessary for determining the means by which a recognized and specific need may be met.

Research (Basic) - a process, the objective of which is to gain fuller knowledge or understanding of the fundamental aspects of phenomena and of observable facts without specific applications toward processes or products in mind.

Research Development/Demonstration - Systematic use of the knowledge and understanding gained from research and directed toward the production of useful materials, devices, systems, or methods, including prototypes and processes.

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Date; 11/9/09 Page 51 of 53

Self-Assessment - Assessments ofwork conducted by individuals, groups, or organizations directly responsible for overseeing and/or performing the work.

Service - the category of economic activity that does not produce manufactured items. In environmental data operations or engineering projects, such activities include design, inspection, laboratory and/or field analysis, repair, and installation.

Shall - denotes a requirement that is mandatory and has to be met.

Should - denotes a guideline or recommendation.

Significant Condition - any state, status, incident, or situation of an environmental process or condition of an engineered environmental system in which the work being performed will be adversely affected in a manner sufficiently serious to require corrective action to satisfy quality objectives or specifications and safety requirements.

Software Life Cycle - the period of time that begins when a software product is conceived and ends when the software product is no longer available for routine use. The software life cycle typically includes a requirements phase, a design phase, an implementation phase, a test phase, an installation and checkout phase, an operation and maintenance phase, and sometimes a retirement phase.

Source Reduction - any practice that reduces the quantity of hazardous substances, contaminants or pollutants.

Standard Operating Procedure (SOP) - a written document that details the method for an operation, analysis, or action with thoroughly prescribed techniques and steps, and that is officially approved as the method for performing certain routine or repetitive tasks.

Supplier - any individual or organization fumishing items or services or performing work according to a procurement document or financial assistance agreement. This is an -inclusive term used in place ofany ofthe following: vendor, seller, contractor, subcontractor, fabricator, or consultant.

Surveillance - the act of monitoring or observing a process or activity to verify conformance to specified requirements.

Technical Review - a documented critical review ofwork that has been performed within the state ofthe art. The review is accomplished by one or more qualified reviewers who are independent of those who performed the work, but are collectively equivalent in technical expertise to those who performed the original work. The review is an in-depth analysis and evaluation of documents, activities, material, data or items that require technical verification or validation for applicability, correctness, adequacy, completeness, and assurance that established requirements are satisfied.

Technical Systems Audit (TSA) - a thorough, systematic on-site, qualitative audit of facilities, equipment, personnel, training, procedures, record keeping, data validation, data management, and reporting aspects ofa system.

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Date; 11/9/09 Page 52 of 53

User - when used in the context of environmental programs, an organization, group or individual that utilizes the results or products from environmental programs. A user may also be the customer for whom the results or products were collected or created.

Validation - an activity that demonstrates or confirms that a process, item, data set, or service satisfies the requirements defined by the user.

Verification - the act of authenticating or formally asserting the tmth that a process, item, data set, or service is, in fact, that which is claimed.

Work - the process of performing a defined task or activity (e.g., research and development, field sampling, analytical operations, equipment fabrication).

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Date: 11/9/09 Page 53 of 53

13.0 LIST OF REFERENCES

American Society for Quality Control (ASQC). 1994. Specifications and Guidelines for Quality Systems for Environmental Data Collection and Environmental Technology Programs, Draft. ANSI/ASQC E4 - 1994, January 1994.

U.S. Environmental Protection Agency (EPA). 1988. Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA. Interim Final. EPA/540/G-89/004.

U.S. Environmental Protection Agency (EPA). 2000. EPA Order CIO 2105.0, Policy and Program Requirements for the Mandatory Agency-Wide Quality System, May 2000.

U.S. Environmental Protection Agency (EPA). 2001a. EPA Requirements for Quality Management Plans. EPA QA/R-2, EPA240/B-01/002, March 2001 (Reissued May 31, 2006).

U.S. Environmental Protection Agency (EPA). 2001b. EPA Requirements for Quality Assurance Project Plans. EPA QA/R-5, EPA/240/B-01/003, March 2001 (Reissued May 31, 2006).

U.S. Environmental Protection Agency (EPA). 2004. USEPA Contract Laboratory Program National Functional Guidelines for Inorganic Data Review. EPA540/R-04-004, October 2004.

U.S. Environmental Protection Agency (EPA). 2005. Guidance on Quality Assurance for Environmental Technology, Design, Construction and Operation. EPA/240/B-05/001, January 2005.

U.S. Environmental Protection Agency (EPA). 2006. Guidance on Systematic Planning Using the Data Quality Objectives Process, EPA QA/G-4. EPA/240/B-06/001. February 2006.

U.S. Environmental Protection Agency (EPA). 2007. Guidance for the Preparation of Standard Operating Procedures (SOPs), EPA QA/G-6. EPA 600/B-07/001. April 2007.

U.S. Environmental Protection Agency (EPA). 2008a. USEPA Contract Laboratory Program National Functional Guidelines for Superfund Organic Methods Data Review. EPA 540-R-08-01, June 2008.

URS Corporation (URS). 2009. Safety Management Standards.

URS Corporation (URS). 2008. Quality Management System Documentation, November 2008.

003017

Attachment 4

URS Corporation Insurance Certificate

003018

y A C O R D CERTIFICATE OF LIABILITY INSURANCE Page 1 of 3

DATE (MM/DD/YYYY)

09/22/2009

8 7 7 - 9 4 5 - 7 3 7 8

Willis Insurance Services of California, 26 Century Blvd. P. 0. Box 305191 Nashville, TN 37230-5191

THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. THIS CERTIFICATE DOES NOT AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIES BELOW.

INSURERS AFFORDING COVERAGE NAIC#

URS Corporation 600 Montgomery Street, 26th Floor San Francisco, CA 94111

INSURER A: National Union Fire Ins Co of Pittsburgh 19445-100

INSURER B: Zurich American Insurance Coinpany 16535-100

INSURERC: Insurance Company of the State of PA 19429-100

INSURERD: Lloyci's of London & Bri t i sh Companies 15792-004

INSURERS: Lexington Insurance Company 19437-000

COVERAGES

THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POLICY PERIOD INDICATED. NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THIS CERTIFICATE MAY BE ISSUED OR MAY PERTAIN, THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO ALL THE TERMS, EXCLUSIONS AND CONDITIONS OF SUCH POLICIES. AGGREGATE LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS.

INSR LTR

ADD'L INSRC TYPE OF INSURANCE POLICY NUMBER

POLICY EFFECTIVE DATE(MM/DD/YYYYI

POLICY EXPIRATION DATE (MM/DD/YYYY) LIMITS

GENERAL LIABILITY

COMMERCIAL GENERAL LIABILITY

CLAIMS MADE | X OCCUR

BFPD

GL919652

JL

5/1/2009 5/1/2010 EACH OCCURRENCE DAMAGE TO RENTED PREMISES (Ea occurence)

MED EXP (Anyone person)

XCU, PERSONAL & ADV INJURY

X I Contractual L i a b i l i t y GENERAL AGGREGATE

GEN'L AGGREGATE LIMIT APPLIES PER:

LOC

PRODUCTS - COMP/OP AGG

POLICY X I JECT

$ 5 . 0 0 0 . 0 0 0

$ 1 . 0 0 0 . 0 0 0

1 0 . 0 0 0

$ 5 . 0 0 0 . 0 0 0

$ 5 , 0 0 0 . 0 0 0

S 5 . 0 0 0 . 0 0 0

AUTOMOBILE LIABILITY BAP938521500 5/1/2009 5/1/2010

ANY AUTO

ALL OWNED AUTOS

SCHEDULED AUTOS

HIRED AUTOS

NON-OWNED AUTOS

COMBINED SINGLE LIMIT (Ea accident) $ 2 , 0 0 0 , 0 0 0

BODILY INJURY (Per person)

BODILY INJURY (Per accident)

PROPERTY DAMAGE (Per accident)

GARAGE UABILITY

ANY AUTO

AUTO ONLY - EA ACCIDENT

OTHERTHAN AUTO ONLY:

EAACC

AGG

EXCESS / UMBRELLA LIABILITY

I OCCUR I I CLAIMS MADE

EACH OCCURRENCE

AGGREGATE

DEDUCTIBLE

RETENTION WORKERS COMPENSATION AND EMPLOYERS'LIABILITY y /N ANY PROPRIETOR/PARTNER/EXECUTIVE H ^ OFFICER/MEMBER EXCLUDED? L?LI (Mandatory in NH) If yes, describe under SPECIAL PROVISIONS below

WC4990858

WC4990859

WC4990862

WC4990857/WC499086 0

PE0801821/PE0801657

6502371

1/1/2009

1/1/2009

1/1/2009

1/1/2009

1/1/2010

1/1/2010

1/1/2010

1/1/2010

„ WC STATU-X TORY LIMITS

OTHER

E.L EACH ACCIDENT $ 2 , 0 0 0 . 0 0 0

E.L. DISEASE - EA EMPLOYEE 2 . 0 0 0 , 0 0 0

E.L. DISEASE - POLICY LIMIT $ 2 . 0 0 0 . 0 0 0 OTHER

Professional L iab i l i ty

w/Limited Contractual -

Claims Made Policv

5/1/2009 5/1/2009

5/1/2010 5/1/2010 $2,000,000 Each Claim

$2,000,000 Aggregate

DESCRIPTION OF OPERATIONS / LOCATIONS /VEHICLES / EXCLUSIONS ADDED BY ENDORSEMENT/ SPECIAL PROVISIONS

C o n t r a c t / J o b Nuinber: B r i n e S e r v i c e M a s t e r Agreement

Re: B r i n e S e r v i c e S u p e r f u n d S i t e Reinedia l I n v e s t i g a t i o n / F e a s i b i l i t y S t u d y

CERTIFICATE HOLDER CANCELLATION

Brine Services Cooperating P a r t i e s El Paso Corporation 1001 Louisiana S t r e e t Houston, TX 77002

SHOULD ANY OF THE ABOVE DESCRIBED POLICIES BE CANCELLED BEFORE THE EXPIRATION

DATE THEREOF, THE ISSUING INSURER WILL ENDEAVOR TO MAIL 30 DAYS WRITTEN

NOTICE TO THE CERTIFICATE HOLDER NAMED TO THE LEFT, BUT FAILURE TO DO SO SHALL

IMPOSE NO OBLIGATION OR LIABILITY OF ANY KIND UPON THE INSURER, ITS AGENTS OR

REPRESENTATIVES. AUTHORIZED REI REPRESENTATI\(E

ACORD 25 (2009/01) C o l l : 2 8 1 3 7 5 1 T p l : 9 2 1 0 4 1 C e r t : 13079644 © 1988-2009 ACORDtORPORATION. All rights reserved.

The ACORD name and logo are registered marks of ACORD

003019

W l l IS CERTIFICATE OF LIABILITY INSURANCE Page 2 of 3 PRODUCER 8 7 7 - 9 4 5 - 7 3 7 8

W i l l i s I n s u r a n c e S e r v i c e s o f C a l i f o r n i a , I n o . 26 Cen tu ry B l v d . P. 0 . Box 305191 N a s h v i l l e , TN 37230-5191

INSURED u^g C o r p o r a t i o n 600 Montgomery S t r e e t , 2 6 t h F l o o r San F r a n c i s c o , CA 94111

1

DATE 0 9 / 2 2 / 2 0 0 9

THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. THIS CERTIFICATE DOES NOT AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIES BELOW.

INSURERS AFFORDING COVERAGE

INSURERA: N a t i o n a l Un ion F i r e I n s Co o f P i t t s b u r g h

INSURERS: Z u r i c h Amer ican I n s u r a n c e Company

INSURERC: I nsu rance Company o f t h e S t a t e o f PA

INSURERD: L l o y d ' s o f London & B r i t i s h Companies

INSURER E: L e x i n g t o n I nsu rance Company

NAIC#

19445-100

16535-100

19429-100

15792-004

19437-000

DESCRIPTION OF OPERATIONS/LOCATIONS/VEHICLES/EXCLUSIONS ADDED BY ENDORSEMENT/SPECIAL PROVISIONS

Anadarko Petroleum Corporation, Chevron Environmental Hanagement Company, ConocoPhillips Company, EI Paso Merchant Energy-Petrolexim Company, HESS Corporation Sunoco, Inc. (R&M), United States Environmental Protection Agency are included as Additional Insureds as respects the General Liability and Automobile Liability policies, where reguired by written contract.

Waiver of Subrogation applies in favor of the Additional Insureds as respects General Liability, Automobile Liability and Workers Compensation policies, where reguired by written contract.

Coll:2813751 Tpl:921041 Cert:13079644

003020

of 3

IMPORTANT

If the certificate holder is an ADDITIONAL INSURED, the policy(les) must be endorsed. A statement on this certificate does not confer rights to the certificate holder in lieu of such endorsement(s).

If SUBROGATION IS WAIVED, subject to the terms and conditions of the policy, certain policies may require an endorsement. A statement on this certificate does not confer rights to the certificate holder in lieu of such endorsement(s).

DISCLAIMER

This Certificate of Insurance does not constitute a contract between the issuing insurer(s), authorized representative or producer, and the certificate holder, nor does it affirmatively or negatively amend, extend or alter the coverage afforded by the policies listed thereon.

ACORD 25 (2009/01) Coll:2813751 Tpl:921041 Cert:13079644

003021