Quality Assurance for Brownfields Grants in Region 5

This covers the following types of Grants:

• Assessment (hazardous substances and petroleum)
• Revolving Loan Fund (RLF)
• Cleanup (site specific; hazardous substance or petroleum)

Which grants need an EPA approved Quality Assurance Project Plan (QAPP)?

All assessment grants, both hazardous substance and petroleum, need a QAPP. (If a current assessment grantee receives a new BF assessment grant, a Pre-QAPP call is needed to determine how to update any existing QAPPs.)

Cleanup grants and RLFs do not need an EPA approved QAPP if the sites being addressed are enrolled in the State cleanup program. (If sites being cleaned up are not in a State cleanup program, please contact your EPA project manager to discuss the need for a QAPP.)

What are the requirements that need to be included in an RFP/RFQ?

Consultants bidding on projects requiring a QAPP should provide the name(s) of a certified lab to perform the analyses on the soil/water/etc. samples that are collected. The certification should include all of the analyses in the matrices of interest (i.e., in both water and soil samples). Some States certify labs under their cleanup programs (such as the Ohio VAP or WDNR program) and may require that these labs be used if a liability release letter for a property is being sought from the State.

For projects in States that do not certify labs for their programs, a National Environmental Laboratory Accreditation Program (NELAP) or other State certification is necessary. A list of these laboratories is available on the internet. Labs to be used for asbestos testing should be National Voluntary Laboratory Accreditation Program (NVLAP) or American Industrial Hygiene Association (AIHA) certified, unless the State program certifies the lab for asbestos analysis (e.g., OEPA VAP for asbestos in soil).

In cases where a grantee receives both hazardous substance and petroleum assessment grants, one QAPP can cover both types of assessments (if one consultant is selected to conduct assessments on both types of sites); the specifics are discussed during the pre-QAPP call. Note: A QAPP is consultant and grant specific.

What is EPA's process for QAPP development, review and approval?

The EPA Brownfield Quality Assurance Reviewer will coordinate a Pre-QAPP call with the EPA Project Manager, the grant recipient and their selected consultant. An example QAPP, a checklist, and a couple of guidance documents will be e-mailed to the grantee and their consultant a week or two prior to the date selected for the Pre-QAPP call. The call typically takes one to one and one-half hours.

The consultant prepares the QAPP according to current EPA guidance, and submits a copy to both the grantee and the EPA QAPP reviewer to start the review process. (For projects managed by EPA staff in the Cleveland office, a copy of the QAPP should also be sent to the EPA project manager.)

The review process typically takes six to eight weeks from receipt of the first draft of the QAPP to get to final sign-off. During this time frame, the QAPP reviewer will typically do a first review within a couple of weeks of receipt, based on workload. Comments on the QAPP will be e-mailed to the grantee, the EPA Project Manager and the consultant (with a cc). Instructions will be provided on how to make any necessary revisions, and upon review of any revisions, a final QAPP will be approved by the EPA.

Please call or e-mail Jan Pels (pels.jan@epa.gov), EPA Brownfields Quality Assurance Reviewer, (312) 886-3009, with questions or to set up a pre-QAPP call once you hire an environmental consultant.