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3.2.2.3.
Test Plan
A Test Plan is a technical planning document for a specific MERC test that integrates the contributions
and requirements of all MERC personnel involved in the test into a clear, concise statement of what needs
to be accomplished, how it shall be done, and by whom. It specifies DQOs, sample collection and field
methodologies, laboratory and analytical methods, and the QA and QC associated with all field and
laboratory activities. The four Test Plan elements include: (1) project management, (2) measurement/
data acquisition, (3) assessment/oversight, and (4) data validation and usability.
The Program Coordinator and QA Manager are responsible for submitting the Test Plan to the MERC
Director for review and approval. It must be submitted to the MERC Director at least 30 days before the
start of a test to allow sufficient time for review and revision, if needed. All Test Plans must be reviewed
and approved by the MERC Director prior any data gathering work or use.
3.2.2.4.
Standard Operating Procedures
It is MERC policy that Standard Operating Procedures (SOPs) are in place for all routine procedures that
affect the quality of products or services, such as sample collection, equipment operation, laboratory
operations, and data management. The goal of an SOP is to ensure that all personnel perform the
procedure consistently over time. SOPs help to ensure the integrity, reproducibility, and quality of data
and must be clearly written with sufficient detail that a qualified individual can perform the procedure
independently. Procedures that are not routine, or that are unique to a test, may be described in the Test
Plan or in written protocols attached to the Test Plan.
SOPs may be developed internally, or may be adopted from approved procedures developed by state and
federal agencies or by organizations that develop standards. Internal SOPs are prepared using the EPA
Document
Guidance for the Preparation of Standard Operating Procedures
, EPA QA/G-6, April 2007.
The source for a SOP must be referenced clearly if it originates from an external source. SOPs should be
reviewed by users on an annual basis, updating the document when appropriate.
3.2.2.5.
Field and Laboratory Notebooks, Forms and Records
Systematic records must be maintained for each BWTS test. Project records must be detailed enough to
track project progress, identify decision points, and support conclusions. Field and laboratory notebooks
are the primary source for laboratory and field observations and measurements; sampling details; and
instrument and equipment calibration and maintenance information. These books serve as a permanent
record of the work. Specific forms are used to record sample collection and analysis data. MERC
personnel are responsible for maintaining notebooks on site; ensuring forms are correctly filled out,
creating electronic copies of notebooks and forms, and storing and archiving.
3.2.2.6.
Technical System Audits
A technical systems audit (TSA) is a qualitative on-site evaluation of sampling and/or measurement
systems associated with a specific BWTS test. The objective of the TSA is to assess and document the
conformance of on-site testing procedures with the requirements of the QAPP and associated SOPs. The
TSA may assess test facilities, equipment maintenance and calibration procedures, reporting
requirements, sample collection, analytical activities, and QC procedures.
The MERC QA Manager conducts a TSA at least once during each BWTS test. TSAs are performed
following the EPA document
Guidance on Technical Audits and Related Assessments for Environmental