17
minimum training requirements. The MERC Program Coordinator and senior research personnel are
responsible for ensuring that staff who acquire, generate, compile, or use test data are familiar with
quality requirements and for verifying that technical staff members are trained in applicable standard
operating procedures and the proper use of sampling and analytical equipment. The PC
will maintain a
record of all QA training taken by staff responsible for BWTS test data generation.
The need for
training or retraining to maintain quality-based qualifications is identified by communication with staff,
observation of work processes, and QA assessments or audits.
3.2.2.
Project-Specific Quality System Tools
At the project level, planning, implementation, and assessment tools are applied to MERC’s data
generation, acquisition, and use. In the planning phases of a project, MERC applies a systematic planning
process (such as the data quality objectives process) to specify performance criteria for data operations.
Project-specific quality system tools include documentation and assessments. Three types of documents
are used for MERC BWTS testing: (1) the Program QAPP, (2) the Test Plan, and (3) Standard Operating
Procedures (SOPs). The Program QAPP is meant to promote uniform testing, and therefore, is a more
general document. The Test Plan gives the specific information needed to conduct a test. If another level
of detail is required for describing test activities, SOPs are included in the Test Plan. During testing,
detailed, systematic records are maintained; and three types of assessments are performed: (1) technical
systems audits (TSAs), (2) data quality audits (DQAs), and (3) data verification and validation.
3.2.2.1.
Systematic Planning and the Data Quality Objectives Process
MERC uses systematic planning to develop BWTS tests and link goals, cost and schedule, and quality
criteria with the final outputs. Systematic planning ensures that all participants understand the needs and
expectations of MERC’s stakeholders and the product or results to be provided by MERC. MERC uses
the EPA document
Systematic Planning Using the Data Quality Objectives Process
, EPA QA/G-4,
February, 2006, as guidance. The Data Quality Objectives (DQO) process is a series of logical steps to
establish performance and acceptance criteria (or data quality objectives), which serve as the basis for
designing a plan for collecting data of sufficient quality and quantity to support defensible decisions about
MERC tests of technology performance. Use of the DQO Process leads to efficient and effective
expenditure of resources; consensus on test objectives; and the full documentation of actions taken during
the development of the test.
3.2.2.2.
Program Quality Assurance Project Plan
The MERC Program QAPP provides an overarching plan that describes the quality objectives and
documents the general, common activities that are to be conducted at multiple locations or over a long
period of time. In contrast to the test-specific QAPP, described below, it serves as an umbrella which
describes in a single document the sampling, analysis, QA/QC, data review, and assessment procedures
that are not site or time-specific but apply in all MERC tests.
The MERC QA Manager, in conjunction with the Program Coordinator, is responsible for developing the
QAPP. The format for both the program and test-specific Test Plans is based on the EPA document
Guidance for Quality Assurance Project Plans
, EPA/QA G-5, December, 2002. The draft Program
QAPP is distributed to relevant MERC senior research personnel for review and comment. Once a draft is
finalized, the document is then passed on to the MERC Director for review and approval. The Program
QAPP is reviewed annually to ensure that its content continues to be valid and applicable to MERC over
time.