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QUALITY MANAGEMENT PLAN
Falcon Refinery Superfund Site ingleside, San Patricio County, Texas
TXD 086 278 058
Preparedfor:
National Oil and Recovery Corporation 3717 Bowne street Flushing, NY 11354
Prepared by:
KLEINFELDER
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3601 Manor Road Austin, Texas 78723
(512)926-6650 (512) 926-3312 FAX
II 9010734
II
K L E I N F E L D E R An employee owned comp/iny
^
000941
QUALITY MANAGEMENT PLAN
Falcon Refinery Superfund Site Ingleside, San Patricio County, Texas
TXD 086 278 058
Prepared for:
National Oil and Recovery Corporation 3717 Bowne Street Flushing, NY 11354
Prepared by:
K L E I N F E L D E R An employee owned company
KLEINFELDER 3601 Manor Road Austin, Texas 78723 (512)926-6650 (512) 926-3312 FAX
August 5, 2005
Copyright 2005 Kleinfelder All Rights Reserved
Unauthorized use or copying of this document is strictly prohibited by anyone other than the client for the specific project.
59752VAUS5R130 Kleinfelder Copyright 2005 Kleinfelder, Inc. 512-926-6650 All Rights Reserved
000942
TABLE OF CONTENTS
1.0 QUALITY MANAGEMENT PLAN IDENTIFICATION FORM 1
2.0 INTRODUCTION 3 2.1 Importance of Environmental Data 3 2.2 Definitions 4
3.0 KLEINFELDER QUALITY ASSURANCE POLICY AND GOALS 5 3.1 Management Commitment 5 3.2 Kleinfelder QA Policy 5 3.3 Kleinfelder QA Objectives 6
4.0 KLEINFELDER QUALITY SYSTEM FOR DATA 8 4.1 Internal Data Operations 8 4.2 Designated Approving Officials 8 4.3 External Data Operations 8
5.0 KLEINFELDER QUALITY SYSTEM COMPONENTS 9 5.1 Data Quality Objectives 9 5.2 Quality Assurance Project Plan Contents 9 5.3 Standard Operating Procedures 10
5.3.1 Preparation of SPOPs 10 5.3.2 Standard Operating Procedure Criteria 10
5.4 Data Processing, Verification and Validation 11 5.5 Data Quality Assessment 12 5.6 Corrective Action 12 5.7 Information and Technology Management 12
6.0 QUALITY SYSTEM ASSESSMENT 15 6.1 Assessment Management 15 6.2 Types of Assessment 15 6.3 Corrective Actions.... ; 16
7.0 DOCUMENTS AND RECORDS 17 7.1 Kleinfelder Records Management System 17
8.0 QA COMMUNICATION / REPORTING / WORK PLAN 19 8.1 Kleinfelder Communication 19 8.2 Annual Report and Work Plan 19 8.3 QA Work Plan 20 8.4 Kleinfelder Meetings 20
9.0 TRAINING 21
10.0 IMPLEMENTATION REQUIREMENTS AND SCHEDULE 22
APPENDIX A - Falcon Refinery Quality Management Organization Chart
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1.0 QUALITY MANAGEMENT PLAN IDENTIFICATION FORM
Document Title:
Project Site:
Responsible Party:
Contact:
Quality Management Plan for Kleinfelder
Falcon Superfund Site Ingleside, San Patricio County, Texas
National Oil and Recovery Corporation (NORCO) 3717 Bowne Street Flushing, New York 11354
Richard Bergner 5718 Westheimer, Suite 700 Houston, Texas 77057
Phone:(713)783-4832
KLEINFELDER 3601 Manor Road Austin, Texas 78723
Quality Assurance Manager:
Project Coordinator:
On-Site Manager:
Health and Safety Manger:
Regional Manager:
Charles Smiroldo
Stephen Halasz
Paul Supak
Ryan Schultz
Clint Harris
Phone: (505) 344-7373
Phone: (512) 926-6650
Phone:(361)854-4774
Phone: (512) 926-6650
Phone:(512)926-6650
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Page 1 Kleinfelder Quality Management Plan
August 2,2005
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Signature Page
Kleinfelder Concurrence
Name Charles Smiroldo Title QuajityjAssurance Manager
Signature
Name Stephen Halasz Title Project Coordinate
Name Paul Supak Title On-Site Manager n-Site Manager
Signature > ^ ^ y y ^ Date 1 ^ / H / t>t.
Signature 4 - ^ I X A / - ^ Q U ^ ' ' ' ^ ^ Date i T - j U I o (^
ai^/Ob
Name Ryan Schultz
Title Health and Safety Manager
Signature V '̂X. ^ L / I ^ Date
Name Clint Harris Title Regkwal Manager
Signature C jPj^^/ jd. ^ Date / ^ / « \ / o U
EPA Approvals
Name Rafael Casanova Title EPA Remedial Project Manager Signature Date
Name Walter R. Helmick Title Region 6 Superfund Quality Assurance
Manager
Signature Date
Name Donald Johnson Title Region 6 Quality Assurance Manager
Signature Date
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2.0 INTRODUCTION
Kleinfelder offers a broad range of engineering and environmental services in the United States. This
Quality Management Plan (QMP) describes Kleinfelder's quality system, which is a structured and
documented management system that describes the organization's roles, responsibilities, policies, and
procedures as they relate to the generation and use of environmental data and the implementation of
environmental technology. This document is intended for use by Kleinfelder managers and staff. The
document provides a link between quality assurance (QA) policy and the implementation of this plan at
Kleinfelder.
This QMP is applicable to all projects performed by Kleinfelder. The personnel on the organization chart
that is provided in Appendix A will ensure that the protocol in this plan is applied to the Falcon Refinery
Superfund Site.
Analytical samples obtained at the site will be delivered to and analyzed at the Severn Trent Laboratories
(STL) facility in Corpus Christi, Texas. As with STL, subcontractors that provide services to Kleinfelder
including consulting, analytical services, drilling services and monitoring services will be required to have
a Quality System that complies with the EPA's guidelines.
The designated Kleinfelder Quality Assurance Manager (KQAM) will be responsible for reviewing and
assuring the quality of the QA programs of subcontractors. Additionally the KQAM will be responsible for
ensuring that the systems work as noted.
2.1 IMPORTANCE OF ENVIRONMENTAL DATA
Environmental data are a critical input to Kleinfelder's decisions to protect human health, the environment
and provide a quality service to our clients. Many of the decisions that are made concerning the
management of the environment and the reduction of risk ultimately require the use of environmental
data. Therefore, it is critically important that decision makers know the origin and quality of the
environmental data used in these decisions.
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The quality of environmental data is known when all components associated with their derivation
(precision, bias, completeness, comparability, sensitivity, and representativeness) are documented.
2.2 DEFINITIONS
The following definitions are essential to understanding the roles, responsibilities, policies, and
procedures outlined in this document
Quality System - A structured and documented management system describing the quality assurance policies and procedures for (1) ensuring that environmental data are of known and documented quality; and, (2) that environmental technology is designed, constructed and operated in a manner to produce the desired environmental results.
Environmental Data - Information collected directly from measurements, produced from models, or compiled from other sources such as databases or literature, which are used for decisionmaking purposes.
Quality Assurance (QA) - An integrated system of activities including planning, implementation and assessment to ensure that environmental data are of known and documented quality, and that environmental technology produces the desired results.
Quality Control (QC) - The overall system of technical activities that measure the performance of a process or item against defined standards to ensure that the process or item meets the predefined standards of the customer.
Quality Assurance Project Plan (QAPP) - A critical planning document for a project or task, describing how data collection activities are planned, implemented and assessed.
Data Quality Objectives (DQOs) - A systematic planning system designed to produce qualitative and quantitative statements that clarify project objectives, define the appropriate type of environmental data, and specify tolerable levels of decision error.
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3.0 KLEINFELDER QUALITY ASSURANCE POLICY AND GOALS
3.1 MANAGEMENT COMMITMENT
Kleinfelder's top management is committed to the development and implementation of the Quality
Management System (QMS) and continual improvement of quality systems. To demonstrate the
commitment management has formulated quality policies and established quality goals for all projects.
The South Texas Regional Manager for Kleinfelder has the responsibility and authority to ensure that
quality is built into all of Kleinfelder's projects by establishing the QMS and an organization with quality
personnel to implement the quality policies.
The KQAM is the management representative that is independent of the operations and reports through
the Health and Safety Manager and the Project Coordinator to the Regional Manager. Responsibilities of
the KQAM include ensuring the implementation and continual improvement of the QMS, identifying
repetitive nonconformities from the QMS and reporting to top managers on the performance ofthe QMS.
The KQAM has the authority to audit, inspect and test office and field procedures, initiate solutions,
identify and record quality concerns, recommend solutions and stop work to correct deficiencies.
Additionally, the KQAM will regularly consult with the Project Coordinator and the On-Site Manger. On all
issues related to the QMP, the KQAM will have access to the Regional Manager.
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Senior management will assess the QMS annually to ensure its continuing suitability and effectiveness.
3.2 KLEINFELDER QA POLICY
Kleinfelder is committed to sound science and quality assurance (QA) practices that will produce
environmental data of appropriate quality to be used for decision making. It is the policy of Kleinfelder that
all decisions which are made to safeguard the environment and protect human health will include a
consideration of the quality of environmental data and/or environmental technology that supports the
decision.
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Kleinfelder policy also includes a commitment by management that the quality system supporting the
generation of data of known quality and effective environmental technology will be implemented as
described in this plan.
The Kleinfelder policy is achieved by ensuring that adequate and acceptable planning, implementation,
and assessment procedures are utilized through all phases of projects/tasks that require the generation of
environmental data and/or the use of environmental technology.
Managers and staff will assure that there are sufficient QA activities conducted by the environmental
programs to provide reasonable confidence that all environmental data generated are scientifically valid,
of adequate statistical quantity, of known precision and bias, of acceptable completeness,
representativeness, and comparability, and where appropriate, legally defensible.
Environmental data quality is the responsibility of all Kleinfelder staff who are directly or indirectly involved
in the generation of data. Senior managers are responsible for assuring that adequate resources,
including personnel, travel funds, and extramural funds, are available to implement the quality assurance
system.
3.3 KLEINFELDER QA OBJECTIVES
Kleinfelder's objectives shall comply with ANSI/ASQC E-4, "Specifications and Guidelines for Quality
Systems for Environmental Data Collection and Environmental Technology Programs", 1994, with respect
to planning, implementing and assessing quality assurance activities. The following elements shall apply:
The data quality objectives (DQO) process, or a similar systematic planning process, shall be used to plan project goals and objectives as they relate to needed environmental data quality prior to the initiation df data collection activities.
QA Project Plans (QAPPs), or equivalent planning documents shall be developed by those staff responsible for designing and implementing a project, study, or task that requires the collection or use of environmental data. QAPPs or other equivalent planning documents shall be approved by the appropriate personnel priorto project implementation.
Senior managers and staff shall receive QA training appropriate for their responsibilities related to data collection or environmental technology.
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• Communication on QA issues and activities shall be maintained among the Senior Manager, project managers and staff.
• Assessments shall be performed to determine the effectiveness of quality systems.
• QA processes shall be designed in the most cost-effective manner without compromising data quality. Continuous improvement in the quality management system shall be emphasized.
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4.0 KLEINFELDER QUALITY SYSTEM FOR DATA
This section describes the quality system requirements for environmental data generated by Kleinfelder.
The overall quality system policies, procedures, roles, and responsibilities are described in this QMP.
4.1 INTERNAL DATA OPERATIONS
Kleinfelder managers are responsible for preparing QAPPs when the projects involve the collection of
environmental data or the use of environmental technology. The KQAM or his/her designee shall review
and approve all QAPPs for data prior to data collection.
4.2 DESIGNATED APPROVING OFFICIALS
A senior manager or the KQAM who has been delegated the authority to approve quality assurance
project plans must meet the following requirements:
• Possess the necessary expertise in project management to review the QAPP.
• Document the QAPP review using a Kleinfelder Policy.
4.3 EXTERNAL DATA OPERATIONS
Each external entity including laboratories, drilling contractors and consultants will have an approved
Quality System that complies with the EPA's guidelines. After the internal review of data or deliverable by
the generating entity, the KQAM will ensure that the reports meet the requirements of the QMP and the
QAPP.
If changes are necessary, the KQAM will contact the designated QA manger of the generating entity and
ensure that the revisions to the report or the process are made. Annually the subcontractors will be
consulted to determine if appropriate changes are necessary to the Kleinfelder QMP/QAPP.
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5.0 KLEINFELDER QUALITY SYSTEM COMPONENTS
Planning, implementation and assessment processes are necessary to effectively conduct environmental
data collection operations. The elements of the Kleinfelder quality system include activities in the
planning, implementation and assessment phases.
The planning process is documented in QAPPs, the implementation phase is performed and overseen by
the data user and/or project manager/leader, and the assessment phase is conducted as specified in the
applicable project planning document. The components and procedures described below are used for the
collection of environmental data by Kleinfelder personnel.
5.1 DATA QUALITY OBJECTIVES
The data quality objectives (DQOs) process is a systematic planning process that is used to delineate
project-level elements. During the DQO process, the elements that are developed include project
management, data generation and acquisition, project assessment and oversight, and data
validation/usability.
The DQOs developed will be used for the detailed design of the investigation and preparation of the
QAPP. The KQAM will be the focal point for providing guidance and review of DQO development.
5.2 QUALITY ASSURANCE PROJECT PLAN CONTENTS
Kleinfelder relies on QAPPs coupled with detailed standard operating procedures (SOPs) to define
specific project QA/QC requirements. In preparing a QAPP, the project manager must identify the project
objectives, sampling design, critical measurements to be performed, and discuss the QC activities to be
conducted during the sampling, analytical, and validation phases of the project.
All Kleinfelder projects requiring collection of environmental data or the use of environmental technology
for submission to the EPA must have an approved QAPP prior to data collection. Exceptions to this
requirement are those projects where immediate danger to human health or the environment is present or
suspected and projects with minimal scope and risk to health and the environment.
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5.3 STANDARD OPERATING PROCEDURES
Standard Operating Procedures (SOPs) are documented protocols for performing certain routine
repetitive tasks. These tasks frequently involve such operations as sample collection, chain of custody,
analysis methods, instrument or method calibrations, preventive and corrective maintenance, quality
control, and data reduction.
5.3.1 Preparation of SOPs
SOPs are prepared by the senior Kleinfelder staff that have determined that a certain task, procedure, or
job function must be performed in a uniform, consistent manner by multiple personnel. It is advisable that
SOPs be prepared by staff who are most knowledgeable in a specific task or procedure. The SOPs are
reviewed by appropriate staff in the user organization, and at times by technical specialists in other
organizations. The SOPs are prepared in document control format by the user and are to be maintained
on permanent file by the originating organization. Senior staff approves the SOP for use.
SOPs are dynamic documents that are revised as needed. SOP revisions may be the result of changes in
regulations, procedures, instruments and equipment, or by inadequacies noted during implementation
and/or audits. Revisions are reviewed and approved as described above.
5:3.2 Standard Operating Procedure Criteria
The following are considerations involved in the development and utilization of Standard Operating
Procedures. SOPs should be:
• Adequate to establish traceability of standards, instrumentation, samples, and environmental data
• Simple, so a user with basic education, experience and/or training can properly use them
• Complete enough so the user/reader follows the directions in a systematic manner through the sampling, analysis, and data handling process
• Consistent with sound scientific/engineering principles
• Consistent with the instrument manufacturer's specific instruction manuals
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The following protocols related to the collection of environmental data will be addressed in SOPs:
General sampling procedures
Analytical methodology
Sample collection devices, storage containers, and sample additives such as preservatives
Instrumentation selection and use
Instrumentation calibration and standardization
Instrument preventative and remedial maintenance
Duplicate, spiked, blank samples and analysis
Field and laboratory quality control procedures
Sample documentation, sample custody, transportation, and handling procedures
Field and laboratory safety
Data management and assessment procedures
Document control
5.4 DATA PROCESSING, VERIFICATION, AND VALIDATION
Data processing includes collection, reduction, transfer, verification, and storage. Precautions shall be
taken each time the data are reduced, recorded, calculated, and transcribed to prevent the introduction of
errors and the loss of information. Data processing requirements are outlined below.
• Collection: Each field and laboratory SOP, as appropriate, shall address the steps that must be used to avoid errors in the sample collection or sub-sampling process.
• Verification: Data verification is the process of evaluating the completeness, correctness, and conformance/compliance of a specific data set against the method, procedural, or contractual requirements. Data verification procedures will be specified in the applicable laboratory SOP, QA Manual, QAPP, or data review SOP.
• Validation: Data validation is defined as an analyte- and sample-specific process that extends the evaluation of data beyond method, procedural, or contractual compliance (i.e., data verification) to determine the analytical quality of a specific data set. Criteria for data validation shall be specified in the applicable QAPP.
• Storage: Each SOP, as appropriate, shall indicate how specific types of data will be stored.
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• Transfers: Each SOP shall describe procedures that shall be used to ensure that data transfer is error-free, and that no information is lost in the transfer. Data transfer steps shall be kept to a minimum.
• Reduction: Each SOP, as appropriate, shall contain procedures for ensuring the correctness of data reduction processes. Data reduction includes all processes that change either the form of expression or quantity of data items. It is distinct from data transfer in that it entails a reduction in size (or dimensionality) of the data set. Each SOP, as appropriate, shall describe procedures for verifying the accuracy of the data reduction process.
5.5 DATA QUALITY ASSESSMENT
Each QAPP includes procedures for assessing the quality of all environmental data generated for
accuracy, precision, completeness, comparability and representativeness.
5.6 CORRECTIVE ACTION
Each QAPP shall include provisions for QA reporting or feedback to the responsible management to
ensure that early and effective corrective action can be taken when data quality falls outside established
data quality objectives (acceptance criteria). Each QAPP shall also include provisions to keep
management informed when corrective actions are necessary.
Corrective action shall relate to the overall QA management scheme including (a) who is responsible for
taking corrective actions; (b) when corrective actions are to be taken; and (c) who follows-up to see that
corrective actions have been taken and that they have produced the desired results.
5.7 INFORMATION AND TECHNOLOGY MANAGEMENT
Kleinfelder's information resources personnel are responsible for all activities relating to the proper
management of computer hardware and software as well as both in-house and project related data
sharing. Management practices extend to include both local and field offices insuring the provision of up
to date computer hardware and software and an adequate workspace environment for all employees.
Kleinfelder will procure hardware and software that meet the performance capabilities and documentation
. requirements or our clients. Document retention methods and times will adhere to the terms and
conditions of our contracts.
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Employees are provided with the computer hardware and infrastructure necessary to meet the project
requirements. Computer hardware is kept current either by upgrading individual components such as
RAM memory and processor speed or procurement of a new computer station. Desktop workstations are
provided to office employees with laptop workstations made available for travel purposes and employees
located in field offices.
Information access and sharing is provided through a secure local area network accessible to authorized
users only. Workstations are user-specific and password-protected. The main server is password-
protected and accessible only by authorized information resources personnel. All wireless connections
include 128-bit encryption and password protection. Kleinfelder configures its server hardware to ensure
redundancy of the disk subsystem. In addition, all data are backed up nightly and stored on backup
media. Backup media is periodically tested to ensure file and system recovery.
Computer software is maintained by information resources personnel and distributed only to select
workstations specific to the trained user. Software is kept current by information resources personnel by
routinely applying all manufacturer supplied patches and updates. Upgraded software packages are
procured when the available enhancements warrant the need for upgrade. Computer software typically
utilized by Kleinfelder includes Microsoft Office© products, Autodesk AutoCad©, Adobe Acrobat© and
Novell GroupWise for electronic mail. In addition, Kleinfelder information Technology personnel utilize
various tools or virus protection and prevention. Each of these products has documentation that meets
the quality assurance standards of the industry and Kleinfelder.
Prior to purchasing any specialized software for modeling or specialized design activities, the information
personnel obtain professional opinions of the necessary products. After purchase, the programs are
rigorously tested to ensure that the output meets the standards necessary to provide quality data.
Testing of the software is performed based on in-house and developer-supplied scenarios for calibration
purposes to ensure proper utilization within the Kleinfelder system. Software used by subcontractors
must comply with standards utilized by Kleinfelder information resources personnel.
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Data management involves the sharing, transfer and availability of data within and to/from the company.
All project specific data is stored on the main server and is accessed via the secure local area network.
Specific data is protected or encrypted to ensure accessibility only to authorized users.
Electronic Data Deliverables (EDDs) are provided when available. All EDDs are verified by the project
coordinator. Prior to delivery of data to end users, the project website, or to the EPA, all verified data is
protected using security enhancements included in the software package and provided in Adobe© pdf
format only.
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6.0 QUALITY SYSTEM ASSESSMENT
6.1 ASSESSMENT MANAGEMENT ^
An effective QA System requires periodic assessment to determine if the system is operating as designed
and to establish a basis for corrective action. At the organizational level, each affected organization will
be assessed against the appropriate QMP.
The KQAM or designee shall review and evaluate the implementation of selected KQMPs. At the project
level, all data collection activities will be assessed against an approved QAPP. The KQAM or designee
shall review and evaluate the implementation of selected QAPPs during the operational phase of the
monitoring activity.
The final project report shall contain the results of this assessment and state whether the data collected
meet the objectives of the project. The QAPP shall ensure that:
• The level of data quality required will be determined and stated in terms of precision, accuracy, completeness, comparability and representativeness, before the data collection effort begins.
• All environmental data generated and processed will be of the quality and integrity established by each QAPP.
6.2 TYPES OF ASSESSMENT
Oversight of the data generation activities at Kleinfelder will be tailored to the nature of the activity and the
associated management and administrative system. Assessments are the principal means in Kleinfelder's
QA Program to determine compliance with established QA Management and Project Plans.
Different types of assessments are used to verify that management and measurement systems are
operating properly, to assess whether data quality is adequately documented, and to evaluate the
management of QA programs.
Four specific kinds of assessments will be used at appropriate times by the KQAM to determine the status
of measurement systems, the adequacy of the data collection systems, the completeness of
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documentation of data collection activities, and the abilities of program management to meet mandated
data collection and data quality objectives.
These four audit types are performance audits, technical system audits, data quality system audits, and
management system reviews. Each type of audit is described below:
• Performance audits are quantitative audits of the ability of an analytical system to obtain reliable data. These audits involve submission of proficiency test (PT) samples as unknowns to laboratories or other analytical systems. The Kleinfelder-selected laboratory routinely participates in these audits as appropriate.
• Technical system audits are on-site environmental assessment activities. The audits are qualitative assessments of personnel, equipment, facilities, procedures, and QA activities.
• Data quality audits are quantitative audits in which data are reviewed and evaluated following collection to determine the quality and usability of the data.
• A management system review (MSR) is an assessment of an organization's ability to implement and manage an effective QA program
6.3 CORRECTIVE ACTIONS
Results of these various types of audits are reported to the KQAM. The KQAM will submit written findings
and corrective actions, along with a specific time frame for responding to the findings. Assessment
corrective actions will be tracked by the KQAM or his/her designee. A written response with a satisfactory
corrective action from the affected organization or project shall be considered as an appropriate
response.
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7.0 DOCUMENTS AND RECORDS
Kleinfelder records come in many forms, formats and storage media. Because of legal requirements,
Kleinfelder is required to create, maintain, and retain their files, records and information as a valuable
resource.
7.1 KLEINFELDER RECORDS MANAGEMENT SYSTEM
Kleinfelder has issued standard operating procedures for managing records. General procedures for
records management are in place in Kleinfelder:
Each Office is assigned record keeping responsibility in accordance with its functional responsibilities and
duties. Records and information created, received, maintained, or acted upon shall be maintained in
accordance with contractual requirements.
Managers and supervisors will be held responsible for ensuring that staff members are adhering to
record-keeping procedures.
Mandatory Records Management training sessions will be provided for all employees, managers, and
contractor staff on record keeping procedures and requirements. Such training classes shall be provided
and attendance required once every three years or as changes in requirements warrant.
Files, records and information shall be created, maintained, and retained in accordance with Kleinfelder
requirements.
Files, records and information shall not be destroyed except in accordance with Kleinfelder guidelines,
requirements and schedules. All records destroyed will have a Certificate of Destruction verifying their
destruction in accordance with such guidelines and requirements.
In addition, Kleinfelder will comply with the document control and management systems as outlined in 41
CFR 101-11, "Creation, Maintenance, and Use of Records," to develop a records management system.
The five steps outlined below are implemented.
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Step 1: Specific responsibility for the development and implementation of the records management program has been assigned to a qualified records manager.
Step 2: Appropriate records management practices are applied to all records, regardless of the medium (e.g., paper, electronic, or other).
Step 3: Kleinfelder controls the creation, maintenance, and use of records and the collection and dissemination of information to ensure that only necessary records are accumulated, that forms and reports used for collecting information are efficient and necessary, that all forms and reports are periodically reviewed, and that records are maintained cost effectively and in a manner that allows them to be retrieved quickly and reliably.
Step 4: Kleinfelder strives to improve correspondence and design forms that are user friendly, and are easy to read, transmit, process, and retrieve.
Step 5: Kleinfelder organizes files so that records can be easily found to ensure that records are complete, and to facilitate the identification and retention of permanent records and the prompt disposal of temporary records.
Documents are reviewed by qualified personnel for conformance with technical requirements and quality
system requirements and approved for release by authorized personnel. Documents used to perform
work, such as SOPs, are kept current by personnel performing the work. Measures are taken to ensure
that users understand the documents. Obsolete documents are not used and are removed.
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8.0 QA COMMUNICATION / REPORTING / WORK PLAN
The purpose of communication is to ensure that staff on different projects can effectively develop and
implement programs, perform activities, and resolve problems related to the generation of environmental
data and the use of environmental technology. To effectively implement the Kleinfelder quality system,
communication must occur between the KQAM and managers and staff. Senior management at
Kleinfelder will ensure that regular discussions are held.
8.1 KLEINFELDER COMMUNICATION
The KQAM shall exchange information with Senior Managers, Project Officers and Technical Staff.
8.2 ANNUAL REPORT AND WORK PLAN
By May 1 of each year, the KQAM shall submit a QA Annual Report and Work Plan to Senior
Management This report shall reflect the implementation status of the Kleinfelder QA Program. The Work
Plan will describe all planned QA activities for the fiscal year beginning in October. The QA Report shall
contain as a minimum the following types of information:
Implementation Status of Kleinfelder QA Program
Revisions to Kleinfelder Quality Management Plan
Significant QA-related needs such as new policies, changes to existing policies, guidance documents, audit protocols, etc.
Data Quality Objectives
Status of QA Program/Projects and Standard Operating Procedures
Assessments conducted
QA Program resources
QA training received and provided.
After the completion of the annual review, a letter will be sent to the EPA attesting to the annual review.
Minor changes will be addressed in the letter; however, if extensive changes are made to the plan a new
document will be prepared. Annual reports whether addressed in letter or report form will include a new
signature page. Every five years a new QMP will be prepared. The same policies will apply for QAPPs.
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8.3 QA WORK PLAN
The QA Work Plan shall contain as a minimum the following types of information:
• Total proposed Kleinfelder full-time employees (FTE) for supporting QA management activities in Kleinfelder.
• Total proposed Kleinfelder FTEs for QA/QC support activities.
8.4 KLEINFELDER MEETINGS
In addition to the regular communication/reporting activities described above, the KQAM, or designee, will
participate, at a minimum, in Annual QA meetings. The KQAM, or designee, will participate in other
meetings and workgroups, which help to advance QA goals and to assist with the implementation of the
quality system.
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000963
9.0 TRAINING
Each manager will ensure that all personnel performing duties that require the use of environmental data
or technology will have the needed education, experience, and training. Formal education and experience
are prerequisites of each project.
Personnel who may require QA training include, but are not limited to, laboratory technicians, analysts,
supervisors, project officers, project managers, and field project leaders. QA training needs will be
identified by supervisors during annual performance evaluations and through career development plans.
Supervisors should contact the KQAM to determine if the identified training needs can be met through in
house training provided by the KQAM staff, or if other sources are needed for the training. The KQAM will
assist the supervisor in locating the most appropriate QA training to meet the need that has been
identified.
The training needs of the KQAM and QA staff are not static, but change as the various environmental
programs mature. Therefore, training needs of the KQAM and staff will be addressed in the Annual QA
ReportAA/ork Plan.
At least annually, the KQAM will present a training course.
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10.0 IMPLEMENTATION REQUIREMENTS AND SCHEDULE
Implementation of Kleinfelder's QA Program requires that each major milestone be identified and
scheduled for accomplishment. Major milestones shall be identified, scheduled, and progress reported in
the Kleinfelder Annual QA ReportA/Vork Plan.
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000965
Appendix A
FALCON REFINERY QUALITY MANAGEMENT ORGANIZATION CHART
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APPENDIX A - FALCON REFINERY ORGANIZATIONAL CHART
Kleinfelder QA Manager Charles Smiroldo
Kleinfelder
EPA On-Scene Coordinator Gary Moore
EPA Remedial Project Manager Rafael Casanova
-
Project Coordinator Stephen Hatasz
Kleinfelder
Field Oversight Manager Paul Supak Kleinfelder
NORCO Contact Richard Bergner
Bergner & Associates
Health & Safety Manager Ryan Schultz Kleinfelder
m F H KLEINFELDER
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