quality management plan · quality management plan (qmp) describes kleinfelder's quality...

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

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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

000944

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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000945

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.


000952

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


000953

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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000955

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.


000957

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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000958

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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000959

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.


000960

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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000961

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.


000962

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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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.

59752\AUS5R130 , Page 22 Kleinfelder Copyright 2005 Kleinfelder, Inc. Quality Management Plan All Rights Reserved August 2, 2005

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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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