Air Force Center for Engineering and the Environment

Frequently Asked Questions on the Uniform Federal Policy-Quality Assurance Project Plan

General
1. Why is AFCEE switching to the UFP-QAPP format?
Because approaches and requirements for QAPPs differ among Federal agencies, AFCEE believes it is necessary to implement a QAPP guidance document that is applicable to any Federal department, agency, or program. This UFP-QAPP Manual was developed to provide a common organizational framework and approach to QAPPs across DoD, EPA, and DoE. It will reduce conflict by providing all who are involved at Federal facilities with a common set of guidelines and expectations.

2. Is the UFP-QAPP an additional AFCEE project planning requirement?
No. The UFP-QAPP will eventually replace AFCEE's Quality Project Plan (QPP), which includes the Model Work Plan, QAPP, Field Sampling Plan (FSP), Health and Safety Plan (HSP), and if applicable, the Construction Quality Plan (CQP). In some cases, based on project or regulatory needs, it may be necessary to submit the Work Plan and FSP as separate deliverables. However, this practice is not the preferred approach and does not facilitate a streamlined review process. It is also recommended that the HSP and CQP be attached as appendices to the UFP-QAPP to facilitate consolidated QPP review. In summary, the UFP-QAPP, with combined or separate Work Plan and FSP and attachments, will be the integrated deliverable version of AFCEE's QPP deliverables. The UFP-QAPP may reference procedures and criteria in the AFCEE Model documents as approved by the project team.

3. When and how will UFP-QAPP be implemented?
Beginning the Summer of 2009, all new and ongoing projects under AFCEE's environmental restoration contracts should use the UFP-QAPP for data collection or analysis efforts. A "new project" within the context of the UFP-QAPP implementation means a project that requires new data collection or new data use. The UFP-QAPP can also be implemented on existing projects that require changes to the existing QPP components where

There are new investigation requirements, or
There are changes in project requirements that need to be documented, or
There are issues that are not already addressed in the existing QPP.

The vast majority of environmental QAPPs will be generated by contractors; therefore, implementation of the UFP-QAPP format will be, at least in part, through contracts. Federal Acquisition Regulations (FARs) already require, when appropriate, that contractors maintain high-level quality standards with a quality system based on existing standards, such as ANSI/ASQ E4, Quality Systems for Environmental Data and Technology Programs - Section 6 (Part B).

Part 2 of the UFP-QAPP provides three tools to assist in implementation of the UFP-QAPP Manual: Part 2A, the QAPP Workbook; Part 2B, the QA/QC Compendium: Minimum QA/QC Activities; and Part 2C, the Example QAPPs. The QA/QC Compendium outlines minimum QA/QC activities that should be included in a QAPP for all CERCLA projects. These minimum QA/QC activities, although developed for the CERCLA process, are transferable to other environmental data collection and use programs. In addition, AFCEE is developing a training program to facilitate consistent implementation of the UFP-QAPP Manual.

4. I already have an approved QAPP. Will I have to totally rewrite it to comply with the UFP-QAPP Manual?
Previously written and approved project-specific and basewide QAPPs will not require revision and will remain acceptable for ongoing data collection and analysis until the projects are completed or project principals have determined that switching to the UFP-QAPP is necessary. Deviations from the UFP-QAPP requirement for new projects must be discussed with, and approved by, the AFCEE CO and COR.

5. Is compliance with the UFP-QAPP Manual applicable to both basewide (facilitywide) QAPPs and project-specific QAPPs?
Yes. Generic QAPPs are written to address elements of data collection that generally do not change from site to site or activity to activity. They are always supplemented by project-specific QAPPs, standard operating procedures (SOPs), and sampling and analysis plans (SAPs), that address issues not specifically covered in the basewide QAPP. The UFP-QAPP Manual specifically allows cross-referencing to other documents that contain relevant information. Approved generic QAPPs should not be discarded, but rather should be referenced in appropriate parts of the project-specific QAPP to help reduce redundancies and create a more focused document.

6. Who should attend the project scoping meetings?
Attendees should be determined by the project complexity and the desired results from the project scoping meeting. Simple projects may require one or two scoping meetings, and complex projects may require several scoping meetings with varying levels of participation from various stakeholders. Ideally, a project scoping meeting should include those stakeholders who are expected to provide inputs during the systematic planning process. These stakeholders should include representatives from the contractor's technical team, the installation (and AFCEE), and regulatory agencies. Contractor representatives may include the Project Manager, Project Engineer, field staff, laboratory personnel, other subcontractors, and quality assurance officers. Installation representatives may include the Field Engineer, Installation RPM, or staff from missions or base services departments to be impacted by the project activities. AFCEE representatives may include the CO, COR, PM, and government technical consultants or subject matter experts (e.g., chemist, statistician, risk assessor, hydrogeologist, etc.). Regulatory agency representatives may include the tribal, state, and federal regulators, as applicable.

7. Is the crosswalk table necessary if all the needed information and documentation are provided in the QAPP? No. The crosswalk table is recommended when it is impractical to include copies of the related reference documents in the UFP-QAPP.

8. Do I need to include all project SOPs in the UFP-QAPP or can I just provide references or URL links?
All project SOPs should be included in each copy of the UFP-QAPP. SOPs can be included either in hardcopies or as a separate attachment in PC-readable media such as CD-ROM, or as specified in the Contract Data Requirements List (CDRL) document. Any exception or special arrangement may be made by the AFCEE CO on a case-by-case basis to protect proprietary procedures.

9. Is the UFP-QAPP applicable to projects that do not require environmental sampling?
Yes. UFP-QAPP's implementation for all new and ongoing projects under AFCEE's environmental restoration contracts applies to both data collection and analysis efforts. Therefore, a "new project" that requires data analysis efforts and does not have a previously-approved QPP should use the UFP-QAPP format.

10. Is the UFP-QAPP Manual applicable to environmental restoration work at overseas installations?
Yes. The UFP-QAPP Manual is used to develop QAPPs for managing the collection and use of environmental data under AFCEE environmental restoration contracts at client facilities located in the continental US and overseas.

11. Is the UFP-QAPP requirement applicable to environmental Performance-Based Contracts (PBCs)?
Yes. The UFP-QAPP requirements were developed to provide a common organizational framework and approach to systematic planning and environmental data collection and use regardless of contract type or vehicle. Most PBCs will probably include a generic QAPP to be supplemented by project- or task-specific QAPPs.

12. Will transition to the UFP-QAPP format cost more or less?
Transition to the UFP-QAPP format may result in an increase of a contractor's initial level of effort because the UFP-QAPP's systematic planning process requires more up-front planning and project scoping than traditional project planning documents. However, it is anticipated that this initial cost increase will be offset or recouped with savings during the project's life cycle.

13. My project does not require all the worksheets, can I print/use only those worksheets that are applicable/needed for my project?
All 37 worksheets should be included in the QAPP. Worksheets that are not applicable should be marked as such with a brief statement explaining why the worksheet is not applicable. Please note that eliminating some of the worksheets may constitute a violation of quality assurance protocol in some EPA regions.

14. The UFP-QAPP uses terminologies that are inconsistent with our project documents (e. g., Method Quantitation Limit, Practical Quantitation Limit, Limit of Detection, Limit of Quantitation, etc.). Can I use our project terminologies or should I follow those in the UFP-QAPP?
AFCEE encourages using the project-specific terminologies throughout the project's life cycle. However, all terminologies should be clearly defined in a glossary within the UFP-QAPP.

15. How do I attach SOPs to the UFP-QAPP?
To simplify QAPP preparation, written SOPs should be included as attachments to the QAPP. If procedures are documented in a separate document, that document should be cross-referenced, and either attached for review and approval (if not already approved) or referenced with sufficient specificity that it can be easily found. Information in attachments to the QAPP can be provided in an electronic format such as portable document format (PDF); on CD-ROM, DVD-R, or other storage media; or on a website.

16. Should the worksheets be completed in strict numerical order?
No. Worksheets can be completed in any order. For example Worksheets 10 and 11 should be one of the first worksheets filled out during an initial project scoping session. AFCEE will provide example sequences that support various project phases.

17. Project plans are typically written in narrative/paragraph format. Why is AFCEE recommending the use of worksheets?
Using the worksheets is recommended for two reasons. First, worksheets are designed to ensure consistent content and presentation of information in a QAPP and use of a consistent format for QAPPs is expected to streamline the review of QAPPs by regulators and others. Second, worksheets are much easier to track and replace. The UFP-QAPP Manual: Part 2A, the QAPP Workbook, provides an automated process to generate worksheets after entering the required information.

The QAPP worksheets can be taken to project scoping sessions and completed during the project planning stage. Subsequently, the worksheet information can be presented in tabular format in the QAPP. If the QAPP worksheets are not used, information required by the worksheets must still be presented in the QAPP, as appropriate to the project.

18. Can I directly reference the SW-846 analytical methods in the UFP-QAPP worksheets?
Yes, only if the documentation includes specific performance options. Note that SW-846 methods include multiple performance options that can vary with desired data quality level. Current SOPs based on SW846 methods are preferred.

19. We are still procuring subcontractors and vendors for the project. Can we submit the UFP-QAPP without the names of these subcontractors and vendors?
Yes; however, all subcontractors and vendors should be clearly identified in the final version of the UFP-QAPP prior to project execution. For draft purposes , To-Be-Determined (TBD) can be used in worksheets or QAPP sections requiring subcontractor or vendor entries.

20. I already have an approved UFP-QAPP. Do I need to update it when project SOPs are updated in the middle or towards the latter part of the project period of performance?
Yes. The UFP-QAPP is intended to be a dynamic document. All updates should be discussed, approved, and documented using the same process agreed upon in the beginning of the project. All UFP-QAPP recipients on record should be provided with the same updated information.

21. Does the UFP-QAPP require a specific number of significant digits for data reporting?
Details of the reporting procedures should be discussed and approved during project scoping meetings.

22. Are there training opportunities for preparing UFP-QAPPs?
Yes. The following Federal agencies have developed a training program on the UFP-QAPP. These courses are open to EPA, DoD, and DoE government personnel and their contractors as well as state regulators.

USEPA's Federal Facilities Restoration and Reuse Office (FFRRO). Training will be offered periodically (for future opportunities see http://www.epa.gov/fedfac/index.htm).
Navy's Civil Engineer Corps Officer School (CECOS) currently offers a 2-day course on preparing UFP-QAPPs. This course incorporates the new directives implementing the UFP-QAPP manual within DoD and EPA. It is a blended learning course where students take two on-line e-learning modules before coming to the classroom portion of the course. Other training courses are also being developed to supplement this course, some of which may be web-based for personnel who cannot attend the classroom instruction.

23. Is there UFP-QAPP guidance for MEC-or MMRP-related projects?
Yes; however, there is limited guidance on the use of UFP-QAPP for MEC- or MMRP-related projects. Example QAPPs can be found in the following websites.

http://www.ert2.org/T2MRPortal/pages/mrqa.html

24. If our subcontractors decide to subcontract their work, do we need to revise/update the UFP-QAPP?
Yes, the UFP-QAPP is intended to be a dynamic document. In general, any change to the previously approved version should be documented and replacement pages be provided to all entities listed in the Distribution List, Worksheet #3, unless specific exception was approved by the project team during the scoping process to not require an official QAPP revision.

25. Can worksheets be revised, expanded, or formatted differently from those shown in the UFP-QAPP Manual?
Use of a consistent format for QAPPs is expected to streamline reviews by the regulators and others. AFCEE recommends that worksheets be used when preparing basewide and project-specific QAPPs to ensure consistent content and presentation of information. To the extent practical, information should be provided in tabular format using the appropriate worksheets. Sufficient written discussion should accompany the tables to facilitate understanding. AFCEE encourages a graded approach when preparing QAPPs and recognizes that specific worksheets may not be appropriate for some projects; and therefore, may not be adopted by the project team. Additionally, a crosswalk table must be included in the QAPP.

Additional tables can be added if there is insufficient space in the worksheets. Certain sections, by their nature, will require more information or written discussion than others. QAPP preparers are encouraged to develop additional tables, as appropriate to the project. Any table added should be identified as part of a worksheet; if the same table is used in more than one worksheet the information should be written once and referenced in later worksheets. This simplifies and ensures thoroughness if and when duplicated information requires updating.

26. Can we submit SOPs that contain expired approval/effective dates if we are in the process of updating SOPs?
No. Each SOP to be submitted with the project QAPP should be current throughout the effective duration of the project or task that it was intended for. It is the contractor's responsibility to ensure that all sampling, analysis, and field procedures that will be used in the project are documented in current SOPs that are referenced in the QAPP.

27. Our SOPs are being updated annually. Does this mean we have to submit new SOPs if the QAPP is for a multiyear project?
Each SOP submitted with the project QAPP should be current throughout the effective duration of the project or task that it was made for. Copies of new or updated SOPs should be provided to all entities listed in the Distribution List, Worksheet #3.

28. Do SOPs submitted with the QAPP need to include the actual signatures of the approvers?
If a copy or electronic version of the SOP is submitted, an actual signature is not necessary. However, all referenced or attached SOPs should be current and approved by the Project and/or Laboratory QA Manager, as required. In this scenario, a signed copy should be present and needs to be included.

29. Who should review the amended QAPP?
AFCEE understands that reviewers and review scope canvary depending on the nature of amendments. Therefore, the review process and reviewers for both minor and major revisions should be established and identified during the project scoping meeting. Ideally, if an approved QAPP must be revised in response to project needs (including changes to project team members), the amended QAPP must be reviewed and approved by the original approval authority in the same manner as the original QAPP. The amendment must contain complete identifying information, as presented on the original QAPP Title and Approval Page (Worksheet #1), with updated signatures and dates. Only after the amendment has been approved can the change be implemented as determined by the project team during the project scoping process.

30. Can verbal approval be used during the QAPP modification process?
Verbal or electronic (i.e., e-mail, fax) approval of modifications may be obtained to expedite project work. Verbal approvals should be documented in telephone logs. Both verbal and electronic approvals should be retained in the project file. Subsequently, the approved modification must be documented in an amendment to the QAPP and submitted to all approval authority, if applicable, for signature approval within seven working days.

31. My company was contracted to prepare a UFP-QAPP using the existing QPP documents which were prepared by another company. Should I include the other company's information in Worksheet #1?
No. The preparer's information required in Worksheet #1 is only for the one preparing the current version. Information on preparers of previous versions and source documents can be provided in Worksheet #2.

Contracting
1. If the UFP-QAPP Manual is the required guidance document for developing AFCEE QAPPs, what happens if the contractor fails to follow it?
The AFCEE Contracting Officer's Representative (COR) and the Contracting Officer (CO) determine whether the Contractor failed to meet the contract requirements, including non-compliance with contract-specified guidance document or templates. The AFCEE CO and Contractor's contracting representative shall determine the proper decision/resolution and follow-on actions regarding contract non-compliance.

2. What is the status of UFP-QAPP contractual implementation at AFCEE?
On July 9, 2009, the Chief, Restoration Program Management Office, issued a memorandum on the UFP-QAPP implementation for Air Force restoration projects. Since then, modifications to the basic contract SOW and corresponding guidance and resource document are underway to reflect the new UFP-QAPP language and requirements. These modifications will be posted on the AFCEE Environmental Contracting Website (http://www.afcee.lackland.af.mil/contracting/contracts.asp) as executed. As required, separate notification may be sent to all AFCEE personnel and Contractor POCs.

Analytical Laboratories
1. Do Quality Assurance/Quality Control (QA/QC) criteria apply to water quality parameters (i.e., DO, TOC, conductivity, ORP, and others) or geotechnical tests?
AFCEE encourages using a "graded approach" when preparing project QAPPs. The use of QA/QC parameters and acceptance criteria should be tailored based on a project's intended use of the results and the degree of confidence needed.

2. Can we use non-EPA analytical methods?
Yes, only if it can be shown that the alternative methods meet or exceed the project DQOs, and DQIs. In addition, alternative analytical methods should be peer-reviewed and must be submitted with proof of demonstration of validation or the same level of method validation and QA/QC data as the corresponding EPA method.

3. Do I need to follow the UFP-QAPP Manual Part 2B, QA/QC Compendium even if our project has previously-approved QA/QC protocols?
Previously approved QA/QC protocols do not need to follow Part 2B, QA/QC Compendium if it is part of a previously approved project QAPP. However, it is the responsibility of the contractor to ensure the QA/QC protocols support the project quality objectives. This should be determined during the initial scoping sessions using a systematic planning process. QA/QC protocols, including laboratory-generated QA/QC criteria, for new or ongoing projects that require compliance with the UFP-QAPP must meet or exceed the requirements specified in the UFP-QAPP Manual Part 2B, QA/QC Compendium and the DoD QSM.

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