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Cleanups at Federal Facilities

Summary of EPA Regional Data Quality "Best Practices" for Federal Facilities

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Project Planning

Practice Description EPA Region Is Practice Documented? Benefits Limitations Measures of Success Current Status
Quality Assurance Project Planning (QAPP) Guidance 1 Region 1, EPA-New England Compendium of Quality Assurance Project Plan Guidance.
Draft Final, 9/98.
Consistent application of QA activities in project planning, implementation, and assessment Applies to EPA-lead and non-EPA-lead projects Adheres to QA/R-5 Allows graded approach to QAPP preparation (level of detail and complexity can be varied depending upon project magnitude and objectives) Emphasizes need for project planning meetings Provides "fill in the blank" worksheets to facilitate QAPP preparation - Worksheets capture critical project information - Completed worksheets become tables in the QAPP - Worksheets minimize inclusion of useless "boilerplate" language in the QAPP Expedites QAPP preparation, review, and approval and decreases costs      
DQO Summary Form 1 EPA-NE-DQO Summary Form Summarizes specific DQOs for each sampling event Copies required for the QAPP/SAP, RSCC/authorizing organization, and data validation report/Tier I cover letter     Current form in use since 1996
Regional QA Manual for CERCLA/RCRA 2 Region 2 CERCLA QA Manual Delineates Region-specific requirements for each step in the data collection process Improves efficiency of project planning Improves efficiency of document review and approval Aids in obtaining data of known and documented quality Enhances the consistency of investigations at various sites Increased costs associated with QA/QC Only applicable to CERCLA sites   Last revised in 1989, current plans are to revise Used for all CERCLA investigations
Regional QAPP Guidance for Air and Water 2 Region 2 QAPP Guidance Saves time and resources Improves connection between project goal and results Improves QAPP preparation efficiency and effectiveness   QAPPs approved sooner Most recent revision 1997
Regional Quality Management Plan 2 SOP for Quality Assurance Project Plan Review. HW-8A, 3/92 Evaluation of QA Work Products Generated by Prime Contractors. HW-4, 7/92 SOP for Reviewing RFI QAPPs. HW-8, 10/94 Ensures that data collected will be suitable for intended purpose Ensures that proposed field collection techniques are appropriate Ensures that analytical methods proposed are of appropriate sensitivity for the project goals     Routine for CERCLA and RCRA projects
Intranet QA Homepage 3 No Provides links to QA documents for project planning, data validation, and QAPP preparation Provides names and telephone numbers of QA contacts for each Division Provides name of contact person for Regional Data Validation Guidances Provides electronic copy of Regional Quality Management Plan and approved Divisional Quality Management Plans     In use since 1998
Project Scoping Meetings 3 No Identifies barriers prior to sample collection/analysis All stakeholders have the opportunity to provide input into site decisions Output is a mutually agreed upon site model, with specific details about data collection, analyses, and data validation Participation at request of Project Manager Shorter TAT for QAPP review and approval Limited need for revisions In use since 1983
Regional Quality Management Plan 3 Region 3 Quality Management Plan. 9/96 Establishes QA policy and program requirements for all environmental measurement projects in the Region Lack of Management System Review findings In standard use since 1996; revised QMP under development  
Technical Review of QAPPs 3 Draft Region 3 Quality Management Plan for Superfund Region 3 QAPP Checklist (optional Region identifies QAPP expectations for the Federal Facility Field work cannot begin until EPA approves the QAPP Reviews for Superfund QAPPs completed by a QA team to ensure consistent reviews   Lack of problems in field and analysis Lack of unusable data  
Quality Assurance Project Planning (QAPP) Guidance 4 Quality Assurance Management Plan for EPA Region 4. RQAM-97001, Revision 1. 5/98 Internet: http://www.epa.gov/region4/sesd/oqa/r4qmp598.html Requires QAPP for all internal and external (EPA funded or mandated) projects that involve data collection Requires adherence to EPA QA/R-5 for QAPP contents Requires use of DQO or similar planning process QA Management Plan has been signed and approved by all Region 4 Division Directors Requires approval of QAPPs by Project Manager/Officer and regional QA Manager Project manager/ officer must be aware of QA requirements and responsible for implementation Not all project managers/officers have same degree of knowledge or expertise in data quality issues Question of who has primary responsibility for data quality for Federal Facilities, EPA, or other Federal organization initiating the project No mandatory QA training for project managers   In standard use;
QAPP checklist to be revised;
QA Management Plan is current and in effect
Training (voluntary) on Agency QA policy and DQOs planned for some program divisions
Pre-QAPP Meetings - Region's policy to meet for all sampling events before QAPP preparation. Meeting involves the lab, the State, Federal Facility representative and its contractor, and EPA site manager and support staff. Purpose of the meeting is to define project objectives and potential quality assurance problems. 5 Quality Assurance Management Plan for the Superfund Division Clarifies project requirements and goals prior to sample collection Expedites the document approval process Saves time and money   Shorter QAPP review and approval process In standard use since 1987
Regional Model QAPPs - Require the use of a model QAPP format, including the use of a "document control format" 5 Yes, regional policy Expedites QAPP approval process Ensures a consistent, complete document submitted for review Institutes mini-QAPPs for small, in-house projects Describes how and when to use QAPP amendments and addenda Document control format allows revisions to be prepared, identified, and reviewed more efficiently   Shorter QAPP review and approval process In standard use since 1991
Technical Review of QAPPs is centralized 6 No Allows tracking in Regional Database (QTRAK) Provides for consistency in application of QA policy requirements Allows maintenance of common problems to be addressed to a Regional QA forum for implementing and working      
QA Officer's position located organizationally under each Deputy Division Chief 6 No Permits functional responsibility and accountability, and strengthens working relationships at all organizational levels      
Regional Quality Management Plan 6 Quality Management Plan for EPA, Region 6 (Q-96-039) Establishes QA policy and program requirements for all environmental measurement projects in the Region Allows Region to make "good decisions" Increased cost and time required to ensure Plan requirements are being implemented, periodically assessed, and improved   In standard use since February 1996
Field Analytical Measurement Technologies, Applications, and Selection, prepared by Region 9 QA Office in coordination with the California Military Environmental Coordination Committee 9 The subject document was published by the Chemical Data Quality/Cost Reduction Process Action Team in April 1996. Hundreds of copies have been distributed at National Federal Facilities Conferences Expedites base closure and return of Superfund sites to beneficial use   Used by Federal Facilities and referenced in their Sampling and Analysis Plans In use since April 1996
Brownfields and Tribal factsheets on planning for data collection activities 9 In Factsheet format Assist Brownfields and Tribal Grant Recipients to effectively plan data collection activities   Contribution to Brownfields and Tribal partners developing better planning documents In use since 1997
Regional Guidance on preparation of Field Sampling; also Regional Guidance for preparation of a streamlined one-time sampling plans 9 Regional Guidance Document Format Provide technical guidance for sample collection planning not available in national QA guidance documents   Contributes to planners developing better planning documents In use since 1989; revised in 1998
Technical Review of QAPPs 10 No Region identifies QAPP expectations for the Federal Facility Field work cannot begin until EPA approves the QAPP     In standard use

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Data Generation

Practice Description EPA Region Is Practice Documented? Benefits Limitations Measures of Success Current Status
Field audit procedures for sampling operations and field laboratories 1 SOP for Technical System Audits, Rev. 0, 6/28/96 Low Stress (Low Flow) Purging and Sampling Procedures for the Collection of Ground Water Samples from Monitoring Wells. Revision 2, 7/30/96 Ensures consistency of data quality from field component Reduces field error     In standard use since 1990
Standard Field Analytical Procedures 1 SOP for Elemental Analysis Using the X-Met 920 Field X-Ray Fluorescence Analyzer. 10/29/96 Region 1, EPA-NE Immunoassay Guidelines for Planning Environmental Projects. 10/96 PCB Field Testing Analytical Methods for Soil and Sediment Samples. Revision 3, 6/21/95 Ensures consistency of data quality from field analyses Promotes use of innovative technologies     In standard use since publication date of each document
Standard Field Analytical Procedures 2 USEPA Region 2 Low Stress (Low Flow) Ground Water Sampling SOP. 3/98 Ensures consistency of data quality from field component Reduces field error     Regional Policy
Field Audits 2 SOPs for audits of some air and water sampling activities SOP for Conducting CERCLA Field Audits. HW-20, 10/94 SOP for Preparing a Technical Systems Audit. HW-27, 7/95 Ensures conformance with field portion of QAPP Audits are expensive (both time and money)   In standard use
Field Oversight conducted by EPA and contractor staff during sampling events 2 No Ensures that approved practices are being implemented in the field Provides technical assistance/assurance to Site Managers      
Split sampling 2 No Provides "check" on field sampling techniques Provides "check" on laboratory analyses      
Field Oversight 3 Field Filtration Policy for Monitoring Groundwater Requiring Metals Analyses (QAD009) Dioxin Sampling and Quality Control Guidance (QAD015A) QA Branch Service Request Form (QAD021) Dioxin's International Toxicity Equivalency Factors (QAD016) Quality Control Blank Definitions (QAD011) Aqueous Sample Preservation for VOC Analyses (QAD007) Data Validation Documents (QAD004) Provide users with existing procedures for sample collection, QAPP review requests, and data validation Clear and concise summaries of procedures All topics are not addressed   In use since 1990; QA Directives to be revised
Standard Field Analytical Procedures 4 Region 4 Environmental Investigations Standard Operating Procedures and Quality Assurance Manual. 5/96 Internet: http://www.epa.gov/region4/sesd/oqa/r4qmp598.html Standardized procedures for sampling design, sample collection, field measurements, and field quality assurance Used in all Superfund, RCRA, and water field investigations performed by Region 4 Science and Ecosystem Support Division Region 4 contractors required to follow SOP and are trained in its procedures and application Not necessarily used by other Federal agencies unless required by the EPA project manager   SOP is current and in effect
Best Practices for detection and Deterrence of Laboratory Fraud, prepared by Region 9 QA Office in coordination with the California Military Environmental Coordination Committee 9 The subject document was published by the Chemical Data Quality/Cost Reduction Process Action Team in March 1997;
hundreds of copies have been distributed at National Federal Facilities Conferences
Contributes to reduction occurrences and elimination of laboratory fraud   Used by Federal Facilities and non-Federal facilities in developing their fraud prevention programs In use since March 1997
Generation of Field-based Data Using Energy Dispersive XRF, prepared jointly with the California Department of Toxics and Substance Control 9 In SOP format Provides guidance on planning and generating adequate QC information for field-based analytical technologies   Adapted by sampling and analysis planners In use since January 1999
Guidance on the use of Performance Evaluation Samples to assess field and lab performance. 9 Yes, in guidance format Provides an effective tool for assessing performance of field contractor and contract labs   Generation of performance results to be used for evaluation of data usability and lab/field oversight In use since 1997
Regional Policy Memo on the requirement that the Federal Facility QA Officer be a Federal employee and have proper QA/QC training 9 Yes, in Region Policy Memo, signed by R9 ARA Remediates potential vulnerability identified by the IG regarding a Federal Facility contractor acting as the QA officer   Federal Facilities designate qualify Federal employees to be QA Officers  
Regional Policy Memo on best practices for collection, preservation, and analysis of soil samples containing volatile organic compounds (VOCs) 9 Yes, in Region Policy Memo, signed by R9 ARA Prevents generation of low bias VOC data in soil samples due to volatilization and biodegradation   Adaption by planners for sample collection in QA and sample plans To be completed by April 1999
Field Oversight - EPA Region 10 conducts field oversight during sampling events by using oversight contractors and EPA personnel 10 No Ensures consistency of data quality from filed sampling     Conducted on a regular basis for PRP-led site work; audits of field operations performed on an as requested basis

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Data Validation and Use

Practice Description EPA Region Is Practice Documented? Benefits Limitations Measures of Success Current Status
Data Validation Guidelines (including the Quality System) 1 Region 1, EPA-NE Data Validation Functional Guidelines for Evaluating Environmental Analyses. 12/96 revision Applies to all programs in Region Ensures consistency of data quality Allows use of project-specific validation criteria Offers three different levels (tiers) of validation to meet project objectives     In standard use since 1988
Data Validation Oversight and Method Modifications Program 1 SOP for Data Validation of EPA/Region 1 Contractors. Rev. 2, 5/26/93 Promotes data quality by ensuring adherence to regional data validation policy     In standard use since 1988
Tiered Data Validation 1 Region 1 Tiered Organic and Inorganic Data Validation Guidelines. Draft, 7/1/93 Includes three tiers of validation (Tiers I, II, and III)
  • Tier I includes a data package completeness check
  • Tier II includes Tier I procedures, plus a review of tabulated QC and sample data
  • Tier III includes Tier I and II procedures, plus a review of raw instrument data
Reduces data validation costs and time Tier II requires 50 percent less time than Tier III Tier I requires even less time
Time savings dependent on case size and fraction   In standard use since July 1993
Electronic Data Validation 1 Guidance Document for Completing Region 1 Data Validation Utilizing CADRE Data Review. 2/95 Data validation performed electronically Reduced data validation costs Only applicable to volatile and semivolatile organic CLP data   In standard use since February 1995
Data Validation Guidelines 2 SOP Evaluation of Metals Data for CLP. HW-6, rev 11, 1/92 TCLP Data Validation. HW-7, Revision 3, 3/93 Organic Data Review for Low Conc. Water. HW-13, rev 2, 10/96 CLP Organic Data Review. HW-15, Revision 2, 5/93 PCDD/PCDF Data Review. HW-11, Revision 2, 8/93 Numerous constituent/method specific SOPs Ensures consistency in data validation Saves time/resources     Standard use
Electronic Data Validation 2 CADRE SOP. HW-28, revision 3, 8/97 Saves time and resources Reduces timeframes associated with completing dv Allows for efficient and effective streamlining of the dv process Not functional for pesticides/PCBs Requires frequent updates   Standard use
Data Validation Summary Report 2   Allows for ready identification of specific data issues Assists Remedial Project Managers interpret data Time and resource expenditures   Standard use
Data Qualification Check 2 SOP Qualification Check of Contractor Validated Organic Data. HW-10, 1/92 Allows for oversight of contractor validated data Provides consistent and systematic approach to data review     Occasional use
Final Report Review for Air and Water 2 SOP available for most forms of final report review, including data validation Ensures accurate reporting and data calculation Evaluates usability of data for intended use     In standard use, but not routine
Data Validation Guidelines 3 Region 3 Superfund Data Validation Policy. 1995 Region 3 Modifications to the National Functional Guidelines for Organic Data Review. 9/94 Region 3 Modifications to the National Functional Guidelines for Inorganic Data Review. 4/93 Ensures consistency of data quality   Useful data to risk assessors/ project managers In standard use
Oversight of Data Validation - For all data obtained from the Contract Laboratory Program (CLP), EPA's contractors complete validation for which EPA performs oversight. At times, EPA will review raw data packages and data validation reports originally validated by other government agencies or private parties. 3 No Provides assurance validation was done correctly     SOPs in development
Tiered Data Validation 3 Innovative Approaches to Data Validation. 6/95 Reduced data validation costs Validation level selected based on data quality objectives (need)     In standard use since June 1995
Electronic Data Validation 3 Innovative Approaches to Data Validation. 6/95 Region 3 Modifications to the National Functional Guidelines for Inorganic Analyses. 4/93 Region 3 Modifications to the National Functional Guidelines for Organic Analyses. 9/94 Use of CADRE reduces redundancy and cost Easier upload to CARDE Electronically can/send data summary forms with appropriate qualifiers to RPMs for easy upload to project file Only applicable to volatile and semivolatile organic CLP data Dependent on accuracy of electronic data from laboratory CADRE does not incorporate all regional modifications; manual data validation must also be performed Not applicable to non-CLP data or data in non- Agency standard format Shorter TAT for data validation Reduced costs for data validation In use since 1998
Data Validation Guidelines 4 Region 4 Office of Quality Assurance Standard Operating Procedures for Contract Laboratory Program Routine Analytical Services. Revision 2.0, 1/99 Data Validation Standard Operating Procedures for Polychlorinated Dibenzodioxin and Polychlorinated Dibenzofuran. Revision 2.0, 10/98 Internet: http://www.epa.gov/region4/sesd Standardized procedures for data validation and reporting via Region 4's Laboratory Information Management System Used for all Superfund contract lab data reviewed by the Office of Quality Assurance Supplements Superfund CLP National Functional Guidelines for Data Review Not necessarily used by other Federal agencies or private sector organizations, unless required by the EPA project manager   SOPs are current and in effect
Data Validation Summary Report - Region requires that a data validation summary be submitted with all reports (e.g., Remedial Investigations) at BRAC sites 5 No Determination whether data quality meets intended use Identification of uncertainties in the data Identification of lab problems Federal Facility submittals are not always as detailed as the Regional example report   In standard use since 1995
Region 9 Tier Data Validation Guidance 9 Yes, in Guidance Document Format Assists the Region, Federal Facilities, States, Tribes, local governments, and their contractors in determining the appropriate level for data review and validation commensurate with project needs. Puts resource and effort where it should be   Consistent adaption and implementation First Draft completed in December 1998
U.S. ACOE - EPA Region 9 PBMS Data Review Guidance 9 Yes, in guidance document format Assists the Region, Federal Facilities, States, Tribes, local governments, and their contractors perform the appropriate level for data review and validation for PBMS analytical methods   Consistent adaption and implementation ACOE to prepare second draft by April 1999
Region 9 Full Data Validation SOP 9 Yes, in typical SOP format Defines Region 9 full data validation SOP for performing Non-CLP data. (This is to include non-$F methods)   Consistent adaption and implementation To be completed by June 1999
Region 9 Guidance on Documentation Requirements for Data Validation 9 Yes, in guidance format Provides consistent specification to laboratories on the necessary amount of documentation to be generated for data validation   Consistently used in Region 9 In place since 1989
Region 9 Guidance on Documentation Requirements for non-CLP Data Validation 9 Yes, in guidance format Provide consistent specification to laboratories on the amount of necessary documentation to be generated for data validation   Consistent adaption and implementation In place since 1997
Oversight of Data Validation - On a regular basis, EPA's contractors and, at times, the EPA Regional QA office validate raw lab packages. When necessary, EPA also re-reviews or performs oversight data validation on raw data packages originally validated by other government agencies or their contractors. 10 No Provides a high level of assurance that validation was done correctly Increased cost and length of investigations   Performed on a regular or as needed basis

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Laboratory Evaluations

Practice Description EPA Region Is Practice Documented? Benefits Limitations Measures of Success Current Status
Performance Evaluation (PE) Samples 1 EPA Region 1 Performance Evaluation Program Guidance. Revised, 7/96 SOP for Using Organic and Inorganic PE Samples. Revised, 8/6/96 SOP for Using PE Samples in Analysis of Polychlorinated Di-Benzo-Dioxins. Revised, 6/22/93 Apply to all programs in the Region Requires one single blind PE Sample per batch of 19 or fewer samples, per analytical parameter, matrix, and concentration level PE samples are linked to the tiered data validation system Potential cost savings if failed PE samples result in reduced payment or non-payment to laboratory Limited range of PE samples available (in terms of matrices, analytes, and concentrations)   In standard use since July 1993
PE Sample Database 1 EPA Region 1 Performance Evaluation Program Guidance. Revision, 7/96 SOP for Using PeacTOOLS System and PERS Rating System. Revision 1, 6/22/93 Provides data quality information on each sample batch Provides lab performance data Only contains lab performance data for labs that have analyzed Region 1 samples   In standard use since July 1993
Laboratory Prequalification for Analytical Services 1 Region 1 Laboratory Pre-Qualification SOP. 3/94 Region 1 Laboratory Audit SOP. 3/94 Method for evaluating contracted and/or subcontracted lab qualifications and ensuring technical capability before obtaining analytical services     In standard use since March 1994
Laboratory Audits 1 Standard Operating Procedure for Technical Systems Audits. 6/28/96 Provides for assessment of lab capabilities for specific programs, projects, and/or methods     In standard use since 1988
Reduced Payment/Data Rejection 1 SOP for Submitting Data for Reduced Payment/Data Rejection. 9/9/91 Cost savings from reduced payments for poor data Means for rejecting unusable data     In standard use since 1991
Split Sampling 1 No       Utilized on an as needed basis
Performance Evaluation (PE) Samples - Region requires use of PEs for air and water, whenever available 2 No Provide assurance that lab analysis is acceptable Limited range of PE sample availability   In standard use
On-site Technical Lab Audit for Air and Water 2 SOP for Laboratory Technical System Audit Ensures conformance with lab portion of QAPP Audits are expensive (both time and money   In standard use, but not routine
Performance Evaluation (PE) Samples 2 Region 2 CERCLA QA Manual Ensures labs can adequately perform analysis Time and resources needed to arrange for, obtain, ship, and interpret PEs   Standard procedure
Laboratory Prequalification for Analytical Services 2 Region 2 CERCLA QA Manual Method for evaluating lab qualifications and ensuring technical capability before obtaining analytical services     Standard use
Laboratory Audits 2 SOP for Preparing a Technical Systems Audit. HW-27, 7/95 Provide for assessment of lab capabilities for specific programs, projects, and/or methods     Standard use
Communication of Laboratory Problems 2 No Ensures prompt resolution of problems as they are encountered Enhances communication between Region, CLASS contractor, and labs Ensures regional TPO is aware of lab performance issues Primarily used for CLP (i.e., for split samples   Standard use
Reduced Payment/Data Rejection 3 No Review Laboratory Quality Management Plans, certification status, and method detection limit studies to assess lab capabilities in meeting needs of project/program Limited to "paper" audit due to limited resources    
Reduced Payment/Data Rejection 3 No       SOP in development
Performance Evaluation Samples 3 No   Limited range (no BRAC)   Performed as requested or as needed
On-site Technical Audits 3 Technical Systems Audit Process for Region 3 Laboratory. 3/98 Onsite performed by Contract Laboratory Program to ensure lab capabilities Limited resources prevent on-site visits to non-CLP laboratories    
Split Sampling 3 No       Done on a regular basis
Communication of Laboratory Problems - For BRAC sites, Region requests that the Federal Facility communicate lab problems during the process, not after the fact 5 No Alerts EPA of lab problems earlier Can involve EPA in determining corrective actions and, therefore, reduce the need for re-sampling Federal Facility does not always cooperate   In standard use since 1996 for problem sites only
Best Practices for detection and Deterrence of Laboratory Fraud, prepared by Region 9 QA Office in coordination with the California Military Environmental Coordination Committee 9 The subject document was published by the Chemical Data Quality/Cost Reduction Process Action Team in March 1997; hundreds of copies have been distributed at National Federal Facilities Conferences Contributes to reduction occurrences and elimination of laboratory fraud.   Used by Federal Facilities and non-Federal facilities in developing their fraud prevention programs In use since March 1997
Guidance on the use of Performance Evaluation Samples to assess field and lab performance 9 Yes, in guidance format Provides an effective tool for assessing performance of field contractor and contract labs   Generation of performance results to be used for evaluation of data usability and lab/field oversight In use since 1997
Performance Evaluation Samples 10 No Provide measure of lab performance Can be time consuming and expensive Used only if lab is to be used on a long-term basis   Performed on an as requested or as needed basis
On-site Technical Lab Audits 10 No Provide measure of lab performance Not performed regularly due to time and expense involved Most labs not used on a long-term basis (used on an event by event basis); therefore, pre-award and on-going lab audits become very expensive   Done on occasion, but not regularly
Split Sampling 10 No Provides measure of lab performance     Done on a regular basis as deemed necessary by the EPA site manager

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Practice Description EPA Region Is Practice Documented? Benefits Limitations Measures of Success Current Status
Sample Tracking Database 1 The Regional Sample Control Center Guidance for the CLP and Delivery of Analytical Services (DAS) Program for EPA-NE. 7/96 NESTS - current database CLPSTS - precursor database Tracks samples from field collection through analysis and validation Includes QC information and validation tier Does not include non-CLP samples collected by other Federal agencies    
Sample Tracking Database 2 No Tracks samples from field collection through analysis and validation and distribution to user Ensures timely response to sample specific issues Time and resource constraints Only used on mega-projects   Site/project specific application only
Quality Assurance Training Program 1 Region 1 Quality System: overview of Region 1 quality system, QA Order 5360.1 CHG 1 briefing, overview of Region 1 quality management plan, and developing quality management plans for States and Tribes Project Planning: overview of the Region 1 systematic planning process, Region 1 QAPP program, project scoping and QAPP preparation, and preparing a generic program QAPP  

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