Explore Our Receipt Format Sample for Quality Assurance

Receipt format sample for Quality Assurance

so uh anyway thank you very much for coming here to discuss or learn about quality assurance um this whole session started because uh actually uh the EPA QA Region Three got audited a few years ago and they after and after method that audit they changed modified upgraded their QA process and that process changed some some things for the way in which we handled quality assurance within the region and there was we noticed uh confusion among several even our Professionals in the licensed remediation Specialists confusion about the new process and so we realized both the professionals are confused certainly the applicants themselves are going to be confused as well so we wanted to create this session in order to help bring some clarity to this hopefully no it's not advancing I mean do you remember to unmute the mic I did remember yeah yes yeah it is now um there's a tech guy out there we may need the tech guy because things are are not advancing unfortunately through either mechanism you can see the USB responding oh what I'm going to do is close this down and reopen I think that's what I'm going to happen hope that restart it and hope that doesn't work on the slideshow again yeah I got them starting it from the beginning and hope that that solves the problem yeah now it's working okay when all else fails restart apologies for that so uh anyway in the aftermath of the changes deciding to do this uh program as we mentioned I was able to assemble a excellent panel of professionals here representing different levels of uh QA throughout the entire system so we have uh Bruce Sawyer with the uh applied to science and quality assurance Branch from Region Three and his boss Kia long oh not boss assurance manager okay okay quality assurance manager for for uh for EPA Region Three as well so at the federal level U.S EPA and then we have Aaron Britton who is uh within West Virginia dep in the Office of Environmental remediation and she is the brownfields program manager and then representing the boots on the ground who's actually doing the primary amount of work is our license remediation specialist Mr Matt Ford who is also the president of Greenbrier Environmental Group I am your host Ross Britton for those of you don't know me and I work also with dep and I'm the environmental toxicologist and quality assurance manager for the Office of Environmental remediation and today what we want to talk with you about is we'll laid off with the EPA giving you the bigger picture issues of QA what is quality assurance what are the documents that are required by any uh QA process within region three going through this this process for brownfields and then Aaron will talk about ways in which we can expedite the QA process the common issues that come up and what happens from at least from a programmatic standpoint what happens when things go wrong and then Matt will finish it off with uh kind of how the licensure mediation Specialists can provide leadership and what are the costs and benefits of that and also from his perspective with boots on the ground in terms of what happens when QA goes wrong and then at the end of that we'll open up for a q a session from you you know question and answers and so if you have any questions just go along feel free to write them down jot them down please hold on to them until uh the end so that we can get through the presentation maybe your question will be answered by the presentations themselves until the end but we will uh welcome those questions at that time and with that I will turn it over to Bruce uh thank you so much uh for introducing us Ross again I am Bruce salier um some of you may know me as the mean guy who rejects your documents sometimes and this is Anthony uh that is a wonderful idea uh I am the quality assurance reviewer and this is my uh co-host Tia long you might know her as the mean woman who rejects your Q [Music] so would you like to stand up as well stand up as the mean woman we're very nice we promise very approachable I just want to set the stage okay so in this session we are going to be setting the stage laying the foundation as you can see from our wonderful optic here laying the bricks for uh what is quality assurance um what's are we looking for in terms of document types and why is it important and so let's just take a moment to talk about what is epa's quality system um in terms of brownfields specifically when we're doing a brownfields project assessment remediation the entire intent the purpose of doing this is to provide competence to developers to the community that it's clean that it's accessible that they can go in they can get boots on the ground they can bolster their economy and in order for any of this to be efficacious to get the results we want we have to have confidence in the data that we are producing from our projects confidence that means we need an appropriate quality of data an appropriate quantity of data the right type of data if we don't have these things if we cannot produce defensible data then all of this was for nulls and so enter quality assurance quality assurance is a system of management practices stemming all the way from the very top down to the boots on the ground level that dictates how work is performed to ensure that we have quality outputs so just really keep in mind the type what kind of type what quality and what quantity of data uh you're expecting to generate as you work through your projects in your redevelopments as licensed remediation specialists grantees so one thing that we do want to drop before we really delve into the document types is that QA should be thought of as a process and not a product um if you wait until the ending stage of your uh I'm sorry I speak English I promise guys this is why all of my review members are so mean because I struggle with my words sometimes don't don't hold it against me too heavily uh if you think of it as a product something that's not going to result to the ends of your project it's lost its value as soon as it has occurred to you as soon as you've confirmed that you are going to have boots on the ground that you're going for with the project you should start thinking about those things I just mentioned what kind of data do I need how much data do I need and if you are not putting forth or you're not putting forth the effort to plan things out from the get-go you're going to be kicking yourself later down the line you might collect data or you might not collect data that could result in rework that could result in having to spend more time and more money redoing things that you could have gotten right if we'd gotten involved sooner um and so I just want to drop this as well we at the EPA if you get us involved in your process as soon as possible we might be able to help you we can provide you with information you might not have we can tell you something you might not have thought of that'll help you work through this process that can speed things up so just bear all of this in mind and so now we're really going to hit the ground running and talk about what is it that we are looking for I don't know the level of familiarity the entire audience has so I'll go into some level of detail on what we're looking for in terms of document types and our hierarchy so if you think about it um in the terms of an umbrella or a tree the upper canopy we'll call that a qmp it's covering everything that is underneath the bed we move down one ring of the ladder that can be a quality assurance project plan and a quality assurance program plan we'll delve into the differences between those two things and how they're applicable to the brownfields program one level below that is a field sampling plan those are site specifics that might work for your program it might not work for your program we'll talk about what that is and at the bottom of it is an sop we're not going to go into Sops in detail but what I will tell you is that there is an expectation for you to have them if you submit them to us we'll read them we might provide you feedback but we are not the approving agency but those policies are very important to have in place in part of your quality system okay so what is a qmp we think of a qmp uh yes that's probably a good acronym to spell out thank you Kia a quality management plan as we abbreviate as a qmp uh we we consider that to be an umbrella document and in this qmp we're describing the management level activities so this is not a technical document this is a quality document this is a management document and so how is this applicable to the brownfields program we can think of it like this let's say that you're in office a county who deals with a lot of lead-based pain and so you need contractors you need employees who are certified licensed Specialists to deal with that kind of work and if you don't have that if you're hiring people willy-nilly who don't have the correct certifications then you're going to have a problem when you get out into the field right and so this is the document where you would go win and you'd say as part of our quality system to ensure that whenever we go out into the field we're going to produce what we need we're only going to hire people with this type of certification we're only going to allow projects to go forward if they need these criteria we're requiring this type of documentation whenever we go out into the field we won't do anything until these standards are met because meeting these standards are what's going to allow us to generate the appropriate type quantity and quality of data that's what's going to help us with our defensible data generation management level that's what you want to think when you hear quality management plan how is the management level going to ensure the quality of the organization and so you might be thinking to yourself well that's all fine and dandy but what does that translate to in practice what is the EPA looking for what should I actually write um and now I'm not going to go through each of the elements that you see up on the screen here in detail uh but the EPA did release an updated standard of what we expect to see in quality management plans in January 2023 this is available online we can send it to you if you have trouble finding it we're always available to talk you through these um but essentially when you are submitting a document to us or when you're generating this these are the elements you want to keep in mind and when we are assessing them we are going to be assessing them for the presence and acceptability of each of the elements you see there before you and so you might be thinking to yourself well some of these I've done this before I've gone through this process some of them aren't applicable to my organization some of them don't make sense to me and that's okay that is okay now what you would have to do in those situations is explain why something is not applicable to you and how you plan to rectify or uh I guess mediates the fact that certain elements aren't present so for example we see this a lot in smaller organizations you guys may have seen comments from us before along these lines uh we require that there is QA Independence you don't want the person who is generating all of your data to be the one checking after themselves so yeah I validated my own data I looked at myself and I decided I've done nothing wrong right that's a little bit questionable right and so we like to see that it QA independence from operations now if you're a one-man show you can't do that but that doesn't mean that you can't work with your contractors to have them look at it that doesn't mean there can't be Independence and so there's ways to work quality into your program no matter how big and how small you are quality can always be a factor in what you're doing and if you have questions again I'm going to keep on dropping this throughout the presentation if you ever have questions about how to do that you can contact us and we'll help you work through that process foreign okay and so the next ring on the ladder that's our quality assurance project plan so if qmp a quality management plan if that's a management level this is a project level document if the qmps are just management and quality this is a technical document and so what we're looking for in terms of a quality assurance project planning clap that is all the complete summation of all technical quality assurance and quality control procedures that we expect to see and that you are planning to implement over the course of a project and so well actually go back to that and that we're going to contrast this to a quality assurance program plan and so this is all of the technical quality assurance and quality control procedures that you are expecting to implement at a program level and so you might be thinking to yourself well Bruce isn't that what you just said about a qapp uh well not quite so a qapp is a project level document a QA PRP is a program level document there is a very fine distinction there in a program level document you do not have any sampling information on there you do not have any sampling information on there that's very important we will delve into why it is important in a couple of slides here but what I want you to take away from this is that in this program plan you are documenting the planning aspects the implementation aspects and the assessment aspects of your program without talking about sampling and so in what instances would I need a clap versus a QA PRP well a quap is all of the elements it has that sampling components so let's say that you have a derelict building it's Prime real estate if you ignore all of the vocs that you breathe in every time anyone goes there an amazing place we'd love to redevelop it however because we have that environmental remediation concern we can't move forward and so you approach the EPA and you apply for a grant an assessment Grant it is a one-off project you go in you do your assessment you perform your remediation depending on the results and then you're done in which case it's a singular self-contained project you would not need to do more than one document now let's say and I know this isn't the case for a lot of you let's say there's multiple sites let's say you're a county with numerous Parcels of land where there are environmental concerns but the the scope of work at each of those individual sites is a little bit different maybe you have five locations that all have VOC contamination they all have svoc contamination so should you go through the process of creating this full bolsterous document this clap every single time well no you don't have to you can have one qaprp and then you can publish supplemental field sampling plans that just have that missing sampling information that information that you omitted from your QA PRP and have those approved and so that's something that can be done on on the planning side that can really expedite your process and Aaron will delve into how we can make this go along even further uh when we get to her phase of the process but just bear in mind there is these differences between these two document types and so how are these two document types assessed well just like we released a new standard for Quality Management plans back in January 2023 we also released a new standard for quality assurance project plans in July of 2023 um some of you may not be familiar or even know that document exists um it had we have not gone into full implementation but I do encourage each one each one of you to uh seek that out and delve into it if you have any questions of course contact us over the coming months we will start assessing documents against that plan or against that standard I'm sorry um and just like with the quality management plan if there is an element that is not applicable to your project or to your organization it is okay to omit it you just have to include information as to why that information is emitted as long as you are talking about the planning the implementation and the assessment of your projects it will be approved as long as you are meeting these criteria in some way they will be approved okay and so now we move on to the next ring of the ladder and these are the field sampling plans these are the site specific plans that I had mentioned when we were talking about the information that is excluded from a QA PRP so a field sampling plan is it can be thought of as a work plan with quality assurance elements integrated into it it should link your contaminants of concern your site history to the work that needs to be performed um it should link that work to your sampling design it should link your sampling design to your analytical approach those are your methods how are you actually going to analyze things and you're just going to link that analytical approach to your overall data quality objectives what did you need to get out of this site remediation and so how are field sampling plans assessed well field sampling plans are also assessed against that quap standard that I mentioned however caveat is they are also assessed in conjunction with their corresponding qaprp there is no such thing as a standalone field sampling plan um and I'm just going to give you an example of why this doesn't work to have a field sampling plan and why it is beneficial to have a qaprp I have received documents in the past in which they have gone into great detail about their site history what was wrong why they wanted to do it and then they get to their analytical approach and they've been talking about vocs and svocs for 100 Pages now and then they choose their methods and they're saying okay so we're going to test for arsenic and so I say well hold on now nothing you have mentioned up until this point has in any way elucidated to me presented to me why you would need to plan your project this way and so that doesn't work and the way you're going to get around that is you're going to have a an umbrella document like a qaprp that's going to say well this is the type of work we're going to do across all of our sites all five of those sites that we developed this qap rp4 and then we're going to have a field sampling plan that is specific to what we're trying to do we're not going to have a knick-knack paddy whack this is the template we're using and that have things analytical methods that don't make sense left in because that's just going to slow the process down that's not good planning so we want to again with what they did would not have produced data of the appropriate type quantity or quality because they would have taken samples if they followed the plan for a contaminant that was not present at the site and so I'm just going to tie this back again why do you need QA and hopefully I did at least a semi-good job of explaining to you why planning is important especially for the brownfields program if you go out to a site if you do not have data that is of the appropriate type quantity or quality that's going to lead to rework that's going to lead to you collecting vocs and then homogenizing them because you didn't know that you needed to have them in a separate container that you had to separate those that's the wrong sampling preservation technique sampling technique that could lead to problems with the lab data being qualified you could take something that could have been five samples and you're done to A month's long process of rework and problems on top of problems and so you just really need to keep in mind and I cannot emphasize enough that at the early stages of your process you have to think what is going to produce a quality result what is going to give me the defensible data that I need what's going to give me the appropriate type quantity and quality of data that I need to move forward and resolve my remediation yeah thank you good okay and I've just linked some resources these slides have been made available to you I've mentioned most if not all of these over the course of this presentation I encourage you to look them up and if you have any questions please contact us again I'm Bruce alier I am the person who will be reviewing most of your documents as a licensed remediation specialist and this is Kia long she is our regional quality assurance manager who specializes in qmp so we are always here to help you all thank you we are back I think you can see Bruce's passion in the presentation but we really are here to help um if you have any questions if you need to reach out to us we really don't bite we are nice people please contact us these are requirements um that EPA has across the board qmps co-ops and field sampling plans um and so um I just wanted to reiterate that we really are a resource so if you need to tap us to call us email us we're here and I can concur they don't bite thank you [Laughter] yes I I agree as well I know this is all kind of a a new thing um new QA procedures for uh Region Three and for West Virginia but um they have been fantastic to work with um and I will say if if at any point you need your um Co-op your qmp your fsp reviewed in an expedited manner for whatever reason for your project just let them know I think we had through our 104k assessment Grant we had a site that really needed to get moving I think we said hey could you get this back in five five business days um and they did and so um I think I just want to you know also agree that they're really good to work with and if your site needs to be expedited they will do whatever it takes and they've been really great to work with yeah okay so what I will cover in my slides today are the two expedited QA options that we have for West Virginia um common QA issues that we see and then what happens when QA goes wrong uh okay so for science with 104k or EPA brownfields assessment grant funding um every site has to do a field sampling plan whether it's a cleanup Grant or you're doing like a phase two um uh field sampling plan through your assessment Grant uh for for this first option that I'm going to be covering it's uh the PCP option or presumptive performance program so PCP that's option one and these sites are all in our West Virginia dep voluntary remediation program or vrp um and so these are cleanup Grant funded sites in our vrp I just want to reiterate that because there is going to be a difference with option number two all right so with the presumptive conformance program or PCP um EPA has recognized that we have an approved Clapper all right qaprp for West Virginia so um we have um uh gone into agreement with EPA to be able to use these uh PCP and MOA options um and because of that it's a more streamlined approach um to be able to get sites through quicker um as far as QA is concerned so um the PCP has a signature page um if your project wants to go this expedited PCP route then the grantee quality assurance manager of Clan has to sign the oer quality assurance manager has to sign which is Ross and then the EPA Region 3 asqab which I applied science qualities brand do I get that right very impressive thank you thank you thank you very much um they all have to publishing and we've done this so far I believe with one site um and that was that was a very quick and easy thing to do um it was no big deal but um so the the PCP um signature page just says okay we will conform with the um uh oer Clapper um and Sops so um which we want we had that intent in mind when we had our new Cropper updated um just in August I believe that was so we want our sites to be able to use this these cleanup Grant sites where so often the the assessment Grant applicants maybe don't have the capacity to write their own quack or they don't have the extra funding available for their consultant to write the clap um and we really wanted this to be usable across all of our cleanup green sites and vrp all right so um when it comes to either the size assessment work plan or field sampling plan that's part of the site assessment work plan and the BRP process when it comes time for review you just have to submit it to dep in the usual vrp process for us to review you don't have to send it to EPA for a review they don't they don't need to review it um but however you do need to send it to them just um so that they can archive it and and we can continue with our review foreign touched on the benefits of of doing it this this way um only dep will review the fsp uh or field sampling plan um we do have a statutory requirement to review our work plans within 30 days if sometimes we need an extension but that has to be agreed upon we usually try to get get it through uh with a 30-day review time frame uh like I said there is no need for the 104k grantee or their consultant to write the clap because um it's covered with by using the oer fapper in our Sops um and like I said the field sampling plan is archived in EPA so as soon as we get receipt from EPA um via email then we can move forward with uh whether it's a reviewed or approved from dep staff um if it's approved we can go ahead and proceed with field sampling um so really the the biggest two benefits of this is you're saving time and money and it that it always comes down to that with every brownfields project you want to save as much time and money as possible goodness okay and just a few considerations um EPA can always go back and review the field sampling plan at any time just to verify quality assurance conformance um if it seems like there's a pretty big issue then EPA can resend the PCP but both the grantee and DEP have rights of appeal and we can you know talk through with this with EPA again they're very easy to talk to and if it was an oversight or something we can get through that um no big deal uh when our Co-op expires which is every five years and we always try to not let it lapse of course um but when it expires the PCP expires as well and so the grantee would just have to re-enroll um by signing a new PCP um a signature page when the new clap group is approved and so we have it ready to go um if you are considering this if your consultant is considering this or lrs we've already got Bruce and Ross's signatures we're ready to go it'll take no time at all to sign off on the PCP um and we can move forward as long as the fsp is sent to both of us and EPA is good with it with email uh receipt okay so if you don't want your site to be enrolled in vrp and sometimes it's not a good fit we usually always try to recommend that cleanup Grant sites do enter vrp so that you get that certificate of completion at the end and that Assurance is also given to EPA as well that the site is cleaned up but sometimes it's not a good fit um or for example the uh if you have a 104k assessment Grant and you have a field sampling plan for a phase two or phase three for example um then those sites wouldn't be in vrp if you're just starting out with assessment so option two is the memorandum of agreement or MOA um and again it's the 104k EPA brownfields assessment Grant uh funded field sampling plans that we're talking about here the Grant tequam and the oer clam again sign off on the Moa signature page um and so this is also again saying you are conforming to The oer Clapper and Sops um but you obviously can document any deviations as you as you see fit um but you also submit the fsp to EPA for their review so typically you know if the site's not in vrp if it's through a different 104k grant for a phase two field sampling plan we wouldn't necessarily we as a dep wouldn't review those anyway so it would go to EPA 4 review um and so a few benefits here uh the site enrollment in vrp I don't want to say is optional but sometimes it it's not a good fit again we always recommend the sites that get cleanup grants go through vrp but sometimes they don't um it is still an abbreviated quality assurance process um and only EPA will review the build sampling plan um there's no statutory requirement for them like for dep but they really try to to get to it as soon as possible I think they are striving for 45 day review about maximum but again if you have an expedited project you just have to let them know and they will squeeze it in if they if they can love this yes they will do there the program we are applying for applied and they review it under this yes thank you Susan yeah the Brownfield projects officer is looking at it for a long distance yes yes I apologize um yes so they uh Susan and Joe are within VA in the back there um so project officers uh have a five to ten day review time window so it's even better um and uh like I said if it's expedited they will they will fit it in sooner um if they can um but again the 104k grantee or their consultant uh do not need to write a co-op because they will conform to using our Cropper and Sops and so you save some time and money not as much as the PCP option um but still you're saving some time and money all right and so some considerations DP does not review this but we we typically win it anyway we we can always review plans we offer that free technical assistance through our Broncos assistance program if you would like us to still review we'd be happy to um so the 104k grantee um cannot appeal this um because he came has to you know review the field sampling plan um as as with the PCP the Moa expires when The Clapper expires um but again it expires every five years and we always try to not have a lapse in time um so the grantee would need to re-enroll in the Moa when a new dep Club is approved all right moving on to Common QA issues so um and I think Bruce touched on this a little bit already but some things that we see um in our brownfields program and also in our voluntary remediation program um so sampling can sometimes be in the wrong location um if it's not you know near sensitive receptors or Source areas um it could be in the wrong depth range and surface and subsurface soils um or samples could be collected in the wrong time of year so some same build samples really need to be collected in the winter versus Summer and we do see that sometimes as well and then for some of our soil sampling for vocs we we touch on this in our pop Urban our guidance manual there are certain screening methods that we require and sometimes um Consultants use you know different screening methods but again you would need to run that by by us um and um sometimes soils are homogenized um when they shouldn't be or some samples are not homogenized when they shouldn't be and I think we're such on this as well sometimes um their uh samples are preserved incorrectly they're using the wrong preservative or it's uh the cooler isn't cold enough um which I think we've all had that happen once or twice I know I have um all right and so some analytical common issues um using the wrong analytical procedure analyzing samples after the holding time expires uh we do see that um every now and then and then not meeting the Precision goals uh the QA Precision goals for RPD of duplicates not meeting accuracy goals for percent recovery of spikes not many sensitivity goals where the reporting limit is greater than our standard and this can happen in pcbs and groundwater hex Chrome and groundwater and some pH is in groundwater for example nataline and dibenza age answer scene foreign goes wrong because inevitably something usually happens um unfortunately so um so you you have to check the data validation and that's a requirement in vrp that we have so much um samples uh data validated um so you just kind of have to go in more closely and say okay what is actually happening um to see if the data does actually meet um the dqos and dqi goals um so and sometimes that takes you know just some extra time uh which can mean not meeting your deadlines unfortunately um and sometimes you do have to just resample for certain criteria or for certain contaminants or Media or at different locations to make those risk-based decisions that we have to in um in our vrp and for grant tours um risk-based decisions are made on the basis of having the confidence in the data so that you actually can see okay what are the risks here what are the potential exposures and Pathways um so that's why we really need to have that confidence in the data and that we're meeting our data goals and DQ bows and dqis and like we say you know garbage is going in the garbage is coming out and we really want to have yeah yeah so and then you know if EPA or if we are making decisions based on this data um then we may question the overall QA process and the decisions that have come after that um and then we may have the applicant or grantee collect more samples unfortunately and of course that's happened we're always like more data more data um but we have to make sure that no one is getting exposed you know um to a too high or too much um uh contamination and that's really the bottom line here we want to make sure we can answer all those questions confidently if we ever get asked in a public meeting or in the future from from the public all right and I think again bottom line is we're here to help um we're excited about these options we really were pushing um to work with EPA to allow these options um and they were listening and they were they were super quick to work with this um and we just thank you all for for doing this and we're happy to help West Virginia and our projects in West Virginia um get through the QA process a little bit quicker all right Max are you gonna figure yes playing garbage so the boarding my name's Matt Ford I'm a licensed remediation specialist um they wanted Tales from the dark side but I didn't want to talk about mine so I did a foia request on other lras I hope you're not in the room sorry so uh leadership role of the lrs in the uh QA process and as they mentioned this isn't a new process necessarily it's just a new emphasis on the existing process so uh but oftentimes we have new grantees so an lrs gets hired by a grantee and we have to help guide and educate that grantee because um you get hired and you say well we need a Q and P and a q app and you go it's going through all these acronyms and they're like we don't hear any of it we hired you take care of it but they need to know right because they're a part they're the grantee they have to really be know the QA process and uh they're an integral part of it um but oftentimes you got to get over that initial hurdle um guidance and education and once you get to that process then often the development of these plans falls to the license remediation specialist so making sure that the quality management plans developed appropriately and um and then helping to decide whether a quality assurance project plan or a quality assurance program plans needed um if you if the grantee has an assessment Grant you wouldn't develop a quiet for an assessment Grant because there are multiple sites that they'll be working on and often when they get the grant they don't even know what sites they're looking at yet um so you can't develop anything specific because you don't know what site it is yet um and then another part is review of existing data many of the sites we work on it's not the first time they've been sampled and there's data that exists out there and is that data does it mean to data quality objectives and going back and do we have enough information to know whether the quality assurance is there for the existing data is another responsibility of the license intermediation specialist and then once the plans are developed our responsibility to make sure the process is followed so we have this oversight and review responsibility and then the implementation piece see a lot of field procedures were mentioned as issues in quality assurance but I know we can all take like everyone in the room can take a few days off but if our field people take a few days off for training it's a problem for the business so uh making sure that what we learn and what we plan makes it to the field so that it's implemented correctly because I know um oftentimes you may have the geologist that's been doing this for 20 years and he has his way of doing things and then an sop changes and sometimes they may not even read the plan or just making sure all that's followed so that you're the most up-to-date procedures are are being completed in the field obviously there's costs and benefits to the club versus The Crab herbs and they went through the process so um anytime there's a plan that needs written obviously time is money when you're paying an lrs or other consultant so anything we could do to Xbox process in this PCP in the memorandum of understanding is great because there are um a lot of money could be saved and timed by being able just to sign those forms and and move on when QA goes wrong Project's 50 rail but uh obviously uh poor plantings a major issue and Aaron went through some of the most common issues that the dep sees but poor planning incorrect field procedures um leads to inaccurate reporting and then increased costs and liability anytime there's a process isn't followed the last thing that an lrs wants to do is make risk-based decisions and close out a site Based on data that isn't of the quality where it needs to be and then human health in the environment suffer and if that happens of course insurance companies get involved because there's liability so wanting to avoid all that awesome thank you thank you Matt uh let's have a hand Round of Applause I can add on to uh that a little bit in terms of you know working with the EPA I will say this process to develop the PCP and MOA options that that we've done this was a two and a half year negotiation problem this is not a small we didn't dream this up overnight now this is from the beginning of when uh Kia first told us that there were there were changes coming and so because we were in the process of updating our clap up at that point to implement what we hoped we thought were going to be streamlined options and then the change from Region Three kind of through a monkey wrench in that whole plan and then we had to re-retool everything so but you know we got there it took a while and usually at the usual speed of government right we got there but we've arrived at a excellent position where we think both EPA and DEP are very happy with what we come up with to give all of you options to get through keyway much more easily just black um so at this point I'd like to open up to see if any of you have any questions for any of our panel members um yes do you have those same agreements with other states Beyond just go ahead speaking to the microphone yeah repeat the question yeah repeat the question do you have the same agreements with other states that you do with West Virginia not yet but we do have can you hear me do I need the mic okay um we do have this agreement and it's available for all of the region three states the PCP and the Moa but I think West Virginia right now is the only state that's taking the opportunity to implement it so um West Virginia has been first yeah we're the guinea pigs yeah but we would like other states to um come into the PCP um I will add the reason that West Virginia is the first is that there is a requirement within the presumptive conformance program I don't like the acronym because that's a schedule one drug I don't know if anything right okay I didn't think it existed before I got hired anyway there is there's a requirement within the uh the QA PRP that certain elements are added into it to ensure a remote more robust quality system uh West Virginia was 99 there to begin with so they were perfectly happy to go over the finish line if you have any questions about what those elements are or how your States might be able to get there it's a bit beyond the scope of what we can cover in the next 15 or minutes or so but please uh reference the slides contact myself or Kia and we will help you through that uh we we really want people to use this program yes thanks and uh along those lines it was it was great from the marketing points as we had just updated The Clapper that made it easier for us to be to do this kind of lasting thing I mentioned guinea pigs earlier I should actually uh give a shout out to uh I consider like the ultimate guinea pig in the room that's Dave corsaro who was the first site to use the PCP and had to go through the Growing Pains of the program shall be said and then so one question I have is uh when you submit it so it will not be called a field safely plan and when we submitted under the VRE yeah we were still called the site assessment work plan yes it'll be yeah so when it gets submitted you guys but what we did was we just took the approval letter and the an asawb and and sent it in yes is that the way you want it I mean you want you want documentation that has been approved by pep right when you did you don't want any drafts nothing like that yeah so they have um by the time it reaches us under the presumptive performance program yes raw it will have already gone through dep all it has all that has to happen at that point is that dep will submit it to uh the corresponding project officer often it's going to be Mr Joe Nowak in the back there who will send it to us we will issue a receipt memo and then you guys are good nothing nothing beyond that but no no draft forms okay so you guys submitted EPA or the degree entities don't know I said we were thinking of them so that's a good thing okay brand new program provided that it's signed by you yeah um I don't know if it's that important though typically documents are only submitted to us through the project officers yes in the case of you we had already received your document it didn't matter so much one way or the other because a project officer had sent it to us um though going forward it would be better if it were through the project officers just because that's how we keep track of Records internally did that answer your question so we needed this a bit yeah yeah exactly so just to repeat reiterate for everyone um you would send it to the EPA project officer and then we would take it from there thanks for clarifying any other questions any other questions yes yes [Music] what is the best assurance that they can provide at the end and the department is completed um for to gain the confidence yeah if you don't get that certificate the question was if you're not in in vrp what Assurance do you have for to give to a prospected developer that everything is okay and I think the best answer to that is probably the fact that EPA is covering you you've got all you've got Federal liability relief at that particular uh point so yeah Joe yeah Joe's got an answer that go ahead Joe yeah on the bigger Brownfield picture of this thing I think like the processes that you um describe involvement using this statement but there are also other options that our office is looking at on a more comprehensive level because you don't have to go through the safe process you can still go to the EPA route and some of those review things might be a little bit longer so we're going to make you know some flow charts for all the four different decisions different paths that go but overall to answer your question as far as you know certifying a site is clean there are basically two methods that we accepted one is going through the New York State certify that it's complete but the other one is the Environmental professional certified experience so it's not EPA because technically it's your work product we're giving you the money you're firing a good consultant and that consultant that should be higher certifies that as a police so that's what goes into our Acres database without being stopped that property as clean as one of those good matters and it's important to remember so you mentioned liabilities for the lrs standpoint that's like once you've got the certificate of completion you can walk away from your liability under vrp actually the liability is still there it belongs to the lrs they assume that liability thereafter that's that's what they're taking on by being the professional at that point that's one other thing when we go into these uh flow charts of abuse things we're looking at squashing this institute what we want to call it something that's a little bit more user-friendly and understandable than the state of BRP processor methods so it's a little more intuitive in terms of everybody understanding what's going on with this processes and not introducing you know another acronym in addition to collapse in Black Version another schedule one drug can we look at this stuff a little bit closer we also want to run ahead of the state so we're all on the same page so then when we roll something out it's a little more understandable to the Republican any other questions yes what is the difference between working under the state the state person is working under an approved Walker within like a 104k grant and why does one get reviewed by the QA the team versus one getting used by RPO like what is the difference between the coffers that makes that fsp able to be reviewed by a three day of the purpose of the set of the QA well part of that the question is you know why a Clapper from like dep approved crapper versus your own site-specific quack right what's or or a program or a program plan if you already have a program if you already have a program plan that's been approved then that's then that's fun as long as it covers what you're what you're trying to do I think is that a fair statement through your standpoint a lot of our sites won't have an EPA approved clap or Clapper ahead of time if you don't have one you have to generate one in which case our Clapper is already pre-approved by the EPA and so you don't have to write one up at that point that's where the advantage comes in if you already have a pre-approved EPA Clapper though for that that is applicable for your your site then that should you should be able to use that without any problem that's why you have options within within the process either of you want to add into that yeah I think what you're asking is why would a 104ks internally designed Co-op or not be covered under the presumptive conformance program specifically like what's the difference between those two crap right well there is a process in the PCP that would not be applicable depending on the 104k and that is that it is going through Ross and Ross is looking at this Ross is not going to look at every single field sampling plan and this that comes out of the state of West Virginia that's correct actually I do yeah yeah okay well that's fair about yeah it's close if it's going through oer right um so because there is that additional level of review that is the uh the premise of the PCP now for things that have their own QA PRP and are uh kind of falling outside of oers Ross's jurisdiction um they can still go through our normal process now the difference is you asked about pre-dayos which is not something we've covered in this presentation um but we're not going to cover that all right no that's fine yeah um yes do you want to answer it I can answer that question yeah you can answer okay but I just want to go ahead yeah so essentially the reason is from a I guess practical Logistics standpoint uh pre-deos as we're calling them and I know these acronyms don't make sense to a lot of you in the room um if you're interested you know come find me after the meeting uh but Lord don't find him that's that's fine right right if you want to go down another EPA Rabbit Hole um is that you whenever you were reviewing a field sampling plan um you cannot just review it independently you have to do a secondary review in conjunction of the quality assurance program plan because the project officers have not been trained or certified to do that um they cannot provide that secondary review which means that someone from QA most likely me is going to have to do it now I know more or less what Ross's qaprp says without looking at it I know what it's covering I might not know what's a 104k grantees internally develops qaprp says um that's going to slow things down reviews so that's going and essentially yeah I'm trying to get there we can't meet the time commitment if it's grading that extra level does that make sense good enough this again is about saving time and money and we're not going to sell you something if we know we can't meet our commitments what what's the point of that if that is yeah okay so I'm glad I couldn't okay excellent thank you uh any other questions I thought I saw another hand go up before that one you still have yes another question this is going to sound very fairly then I apologize in advance but one question is how much interaction proactive interaction does the BPA and gpp have on the front end for construction and of structures as well as sites now so that um 10 years 20 years from now we're not having conversations about Brownfield cleanup but if if the construction we saw something that is about to be done uh yesterday and that was wonderful to see those sites being reclaimed reclaimed and repurposed however you wonder okay they're putting new Talent they're putting they're doing these things how do we know that that's not causing a future ground-filled problem in 20 years for those that come after us we don't yeah uh I mean and it's just kind of like the pfas situation there's always going to I mean it's job security unfortunately but there's you know that and that's called an emerging contaminant so there's probably always going to be something in 10 or 20 years um 20 years it was Vapor intrusion um 20 years from now who knows what it will be um we we try to you know have a list of Brownfield sites we try to coordinate with EPA as much as possible um but so so many times it's you just don't know you don't know until there's a little bit of funding either through dep or EPA to assess a site and then you know as soon as as soon as we know you know we can coordinate with one another we can find more pots of funding um but there's just like like he has said there's no magic ball um you know there's thousands and thousands of Brownfield sites in West Virginia there's hundreds of thousands throughout um the U.S so you have anything to say to that yeah I mean like they're saying there's no way to spend people like once you've cleaned up a site from them becoming Believers themselves you know they become reliable for all that stuff but there's also sites that might have you know existing conditions or contamination that's left in place and that's where we get into like certificate or completion institutional Controls and Engineering controls that they're supposed to abide by so they're going to be Excavating through an attack or something like that you're supposed to bring DDP back into the picture and not just do this stuff on your own so there's like various scenarios and I guess if you go through this certificate of completion we go back and reinspect these places what are the operations going on or there isn't some type of latent leak contamination going on so I guess going through that route is adds that other layer to that and not going through the New York you know wouldn't know because it's probably fall behind the scene right so if a site that goes through BRP has institutional or engineering controls we do review annual inspections that the property owner should be sending to dep and we review that every year if we don't receive that inspection then we send out a letter saying hey we actually have several from several sites from early the early days of the program where the state actually has to perform the inspection and we do that on an annual basis as well so that's the benefit of the site going through vrp but Eileen for example for a site with asbestos we don't regulate that through vrp and so it wouldn't go through our program um and you never know what the next the next thing either in building materials or you know underground storage tanks whatever the case may be you know in 10 or 20 years that may cause a spill or release of contamination imagine you're thinking that um well I mean it was a hard question to answer because there are new chemicals developed every day yeah and I remember stories of like we used to play with Mercury you know and you can't ask for better paint than lead paint I mean it's just the reality of it then as we develop new products um but there are I mean there are a lot of checks and balances to do chemical development but I mean we see spills of things that have never spilled before and we don't know what the uh mchm yeah well it was an image but yeah I mean that's one where we didn't know what the toxicity of that was so he's talking about the elk Rivers building and Charleston for those of you want to know where remember bad memories but yeah I mean those things happen so yeah but the DP and other regular do good job ones like this whole B fast issue it's yes you know being on the Forefront of that yeah and since pfas has been mentioned a couple times I'll put in a plug for a panel uh I know Charlie and Ruby up here for EPA and myself and I don't think none of Matt is here but anyway oh yeah and Lydia who was heading to pfas panel uh our we have a session at 3 or 3 15 I can't remember is right around there to discuss pfas if you're not familiar with it and and as a toxicologist in that pfas of course is the big one that's on the horizon that's the trained about to arrive in the station but you know from my standpoint I'm on looking at phthalates as coming in right behind them so keep that on your radar as well any other questions for our panel at this point these have been good questions and good discussions Dave would you actually like to say something about your experience in terms of you know uh things to help with since you are a guinea pig you have any words of wisdom for anybody else I think we just got caught up in on timing issues yes we were submitting at the same time and a lot of this was going on and it was just a lot of starts and stops and and now that it's in place I think it's going to help a lot yeah and um I think that's that's the biggest thing I think we just got caught up in the timing of all this yeah yeah and uh yes you did yeah I guess I guess we're all submitted now I just want to hurt you today I'm glad all this I'm glad all this happened and and uh well and thank you for being the prod that helped get us to this point as well anybody else with the question or a comment if not then I think we can break for lunch I think is next oh yeah yeah that's it thank you for the panel