APPENDIX A - maine.gov...6.3 field data management 24 6.4 document preparation and control 25 6.5...

APPENDIX A

ERM Quality Management Plan &

Summary of Personnel Qualifications

QUALITY MANAGEMENT PLAN

Quality Management Plan

October 2019

Project No. 0533184

Environmental Resources Management, Inc.

One Beacon St., 5th Floor Boston, MA 02108

617-646-7800

Quality Management Plan

October 2019

Project No. 0533184

QUALITY MANAGEMENT PLAN

Lyndsey Colburn, P.G. Partner-in-Charge

Stacey Braga, P.E. Project Manager

Environmental Resources Management, Inc. One Beacon St., 5th Floor

Boston, MA 02108

ERM i PROJECT NO. 0533184 QUALITY MANAGEMENT PLAN OCTOBER 2019

TABLE OF CONTENTS

1.0 INTRODUCTION 1

2.0 MANAGEMENT AND ORGANIZATION 2

2.1 MANAGEMENT APPROVAL 2

2.2 QUALITY ASSURANCE POLICY 2

2.3 ORGANIZATION 3

2.4 RESPONSIBILITIES 3

2.5 PROJECT ACTIVITIES THAT REQUIRE QUALITY MANAGEMENT 5

2.6 COMMUNICATION OF QUALITY SYSTEM 7

2.7 DISPUTE RESOLUTION 7

3.0 QUALITY SYSTEM COMPONENTS 8

3.1 IDENTIFICATION OF QUALITY SYSTEM COMPONENTS 8

3.2 QUALITY SYSTEM TOOLS 13

4.0 PERSONNEL QUALIFICATION AND TRAINING 14

4.1 TRAINING POLICY 14

4.2 TRAINING PROGRAM MANAGEMENT 15

5.0 PROCUREMENT OF ITEMS AND SERVICES 17

5.1 ROLES, RESPONSIBILITIES AND AUTHORITIES 17

5.2 METHODS FOR QUALIFYING SUBCONTRACTORS 18

5.3 REVIEW PROCESS FOR SERVICES AND EQUIPMENT 20

6.0 DOCUMENTS AND RECORDS 23

ERM ii PROJECT NO. 0533184 QUALITY MANAGEMENT PLAN OCTOBER 2019

6.1 PROJECT CONTROL REQUIREMENTS AND IMPROVEMENTS 23

6.2 DOCUMENT DATA MANAGEMENT 23

6.3 FIELD DATA MANAGEMENT 24

6.4 DOCUMENT PREPARATION AND CONTROL 25

6.5 DOCUMENT REVIEW & REVISION 26

6.6 DOCUMENT APPROVAL 27

6.7 DOCUMENT TRANSMITTAL 27

6.8 DOCUMENT DISTRIBUTION 27

6.9 RETENTION 28

6.10 CONFIDENTIALITY 29

6.11 CHAIN-OF-CUSTODY 31

7.0 COMPUTER HARDWARE AND SOFTWARE 33

7.1 PURPOSE 33


7.3 INFORMATION PROTECTION 36

7.4 PROCESS FOR MANAGING COMPUTER HARDWARE AND SOFTWARE 37

8.0 PLANNING 38

8.1 PLANNING PROCESS 38


8.3 PROJECT TEAMS 39

8.4 QUALITY ASSURANCE 40

8.5 QAPPS 41

ERM iii PROJECT NO. 0533184 QUALITY MANAGEMENT PLAN OCTOBER 2019

9.0 IMPLEMENTATION OF WORK PROCESSES 43

9.1 WORK PROCESS PROCEDURES 43

9.2 MANAGEMENT OF PROJECT ACTIVITIES 44

9.3 STANDARD OPERATING PROCEDURES (SOP) 46

10.0 ASSESSMENT AND RESPONSE 50

10.1 QUALITY SYSTEM REVIEWS 50

11.0 QUALITY IMPROVEMENT 53

11.1 QUALITY IMPROVEMENT PROCESS 53

LIST OF APPENDICES

A ERM Corporate Organizational Chart

B Project-Specific Organizational Chart

C Variance Request Flowchart

ERM 1 PROJECT NO. 0407067 QUALITY MANAGEMENT PLAN MAY 2017

1.0 INTRODUCTION

This Quality Management Plan (QMP) was prepared by Environmental Resources Management, Inc. (ERM) for use in preparation of the Project Plans associated with geotechnical and drainage assessment activities as well as site security to be implemented at the Keddy Mill Site, Windham, ME.

The objective of this QMP is to describe ERM’s quality system. The QMP is a management tool that documents ERM’s system for planning, implementing, documenting, and assessing the effectiveness of activities involving environmental information collection and environmental remediation technology design, construction, and operation. As intended by the U.S. Environmental Protection Agency (EPA), the QMP is an umbrella document that sets a framework for quality within the performance of individual projects by a company. The contents of the QMP include quality policies and procedures, criteria for and areas of application, and associated roles, responsibilities, and authorities.

This QMP was prepared to meet the applicable requirements of the EPA document EPA Requirements for Quality Management Plans (EPA/240/B-01/002, March 2001, Reissued May 2016; also referred to as EPA QA/R-2) and the American National Standard Institute/American Society for Quality (ANSI/ASQ) documents Specifications and Guidelines for Quality Systems for Environmental Data Collection and Environmental Technology Programs (ANSI/ASQ E4-1994) and Quality Management Systems for Environmental Information and Technology Programs (ANSI/ASQ E4-2014). The QMP was prepared by the QA Manager with assistance of designated qualified staff.

This QMP applies the graded approach specified in EPA QA/R-2. The quality systems that are discussed in this QMP are intended to meet the quality objectives for the Project Plan components of the project. The structure of this QMP is consistent with that specified in EPA QA/R-2.


2.0 MANAGEMENT AND ORGANIZATION

The purpose of this section is to document the overall policy, scope, applicability, and management responsibilities for ERM’s quality system

2.1 MANAGEMENT APPROVAL

The approval of this QMP is indicated on the signature page included herein. The ERM management and senior staff responsible for the project have personally indicated their commitment to quality and execution of the policies contained in this QMP, and the overall ERM quality policies, by their signature.

2.2 QUALITY ASSURANCE POLICY

Quality is a culture that permeates the ERM organization, and ERM quality systems provide guidelines and procedures that address each operation as a vital link in the chain of daily processes. ERM seeks to consistently produce quality services and work products that meet these requirements. This means that each person in the organization understands his/her role and responsibilities, executes them in a professional manner, and provides the self and independent review of the input provided. Each member of the ERM team provides quality communication and service on ERM projects, and always strives for continuous improvement. ERM management has made a commitment to institute and enhance a formal awareness, training, and measurement program to ensure quality throughout the organization.

ERM’s quality assurance/quality control (QA/QC) activities form the basis for the ERM quality system. The goals of the ERM QA Policy are to ensure that the environmental information collected by ERM and its subcontractors are of sufficient nature and quality for their intended use, and to ensure that ERM-led environmental remediation technologies are designed, constructed, and implemented in keeping with the remediation performance objectives for the project.

ERM’s quality system is designed to achieve the following criteria:

Comply with related international, national, and corporate laws, regulations, rules, and requirements;


Maintain a key focus on understanding and fulfillment of project requirements, providing sustainable solutions and high quality services;

Focus on ERM people, providing appropriate equipment and training, and strongly implementing systems for their health and safety; and,

Continually improve the range and quality of ERM services and management systems, and striving to increase ERM clients’ satisfaction.

2.3 ORGANIZATION

From an internal operations standpoint, the ERM Group is organized as four operating regions around the globe - North America, Europe/Middle East/Africa, Asia Pacific, and Latin America. The North American component conducts activities and offers services through seven multidisciplinary environmental consulting operating companies. Each operating company offers regional services while having access to the resources of the entire ERM Group. ERM Consulting & Engineering, Inc. is a legal entity that represents one of the seven North American operating companies and has primary responsibility for the development of business and the delivery of services in the northeast of North America. The ERM, Inc. corporate organizational chart is included as Appendix A. This project is being conducted under the auspices of this entity, and represents a subset on this chart. The project-specific organizational chart is included as Appendix B.

2.4 RESPONSIBILITIES

For each project, ERM assigns a Partner-in-Charge who has ultimate responsibility for the quality of project-specific activities and deliverables. Where applicable, ERM designates additional, independent QA personnel to provide third party activity-focused QA/QC checks (e.g., construction quality assurance, field data verification, laboratory data review). These independent reviewers have project as well as independent reporting authority to access the ERM Business Unit Managing Partner (BUMP) who is responsible for all activities within ERM Consulting & Engineering, Inc.


As described above, ERM’s Partner-in-Charge has final responsibility to the client for the quality of project activities and deliverables. The Partner-in-Charge has primary responsibility for development and implementation of the QMP and QA program. The Partner-in-Charge is supported by the QA Manager to ensure that the QA objectives are met and procedures are followed throughout the project team. Both the Partner-in-Charge and QA Manager have full independence in executing the policies described in the QMP. The Partner-in-Charge, Project Manager, and/or QA Manager perform the majority of the quality assurance functions. The specific role is determined on a project-specific basis and established at the beginning of the project. The QA Manager may also have a designated qualified person to perform some activities. This person will have training or expertise in performing the work.

It is the responsibility of the Partner-in-Charge to:

ensure that all client requirements are clearly identified, understood and met;

ensure that ERM’s financial and commercial interests are safeguarded;

oversee proposal and project progress;

ensure that review procedures are properly undertaken;

control project budgets and expenses; and

ensure that all members of the project team are informed regarding the quality objectives of the project, and the quality procedures to be utilized.

For all of its projects, ERM assigns a Project Manager. It is the responsibility of the Project Manager to:

ensure the QMP procedures are properly followed during proposal preparation and project progress;

client requirements are fully understood;

project team members are properly briefed and monitored;


all client deliverables are properly reviewed and signed off in accordance with the requirements of the QMP; and

ensure invoices are sent out in accordance with the invoicing schedule.

The QA Manager is designated to provide independent QA checks for project-specific activities and deliverables. The QA Manager has been delegated the responsibility and authority to develop and oversee implementation of the quality systems on a project basis and ensure:

the QMP is implemented by all staff and is kept up to date and relevant to ERM’s needs;

QMP implementation is regularly reviewed by the management team and appropriate actions are taken to respond to any issues identified; and

ERM’s focus on achieving client satisfaction is understood by all staff.

At the beginning of each project, the Partner-in-Charge and/or Project Manager chairs a project kick-off meeting or prepares a team brief in which this quality discussion is executed, and the QA Manager’s role and authority is described in detail.

The QA Manager reports directly to the Partner-in-Charge, and is at the same level as the Project Manager (to whom the bulk of the project team reports). Groups that will be generating, compiling, and evaluating project data report directly to the Project Manager. Because the QA Manager does not report to the Project Manager, the QA Manager role is not influenced by the individual directing data management activities. Furthermore, the QA Manager has direct access to the Partner-in-Charge, and thus can influence the project’s and company’s quality system. A project-specific organizational chart is provided in Appendix B.

2.5 PROJECT ACTIVITIES THAT REQUIRE QUALITY MANAGEMENT

Quality assurance is vital to support the daily activities and services performed by ERM. The primary technical activities or programs that require quality management include the following elements:


Personnel training: provide management and staff with appropriate training to enable the execution of work in a responsible, safe, and technically-sound manner;

Procurement of equipment and services: provide tools to properly secure equipment and services from qualified suppliers;

Document and data management: establish procedures for filing and retention of documents, confidentiality, and review and use of data;

Information technology (computer hardware and software): establish systems for purchasing, using, and maintaining computer hardware and software; and

Technical evaluation and project design: quality assurance for the interpretation of technical data and development of engineering design primarily consists of ensuring involvement of qualified staff and review by senior personnel.

Other project specific tasks that require quality management include the following:

Project planning and strategy development;

Field activities, including measurements and sampling;

Data collection, evaluation and reporting;

Preparation of plans, reports, correspondence, and other documents or deliverables;

Document preparation and communication;

Engineering analyses, design and construction oversight;

Coordination and community relations;

Health and safety maintenance;

Subcontractor performance; and

Accounting procedures and invoicing.


2.6 COMMUNICATION OF QUALITY SYSTEM

ERM ensures implementation of ERM’s quality system through communication at two distinct levels. First, the actions used by company management to ensure understanding and compliance with company-wide policies include dissemination of information, staff training, and enforcement of company programs. Periodic communications, meetings or updates at the local offices are held to reinforce compliance with the company policies. ERM also maintains an intranet system accessible to all employees where all current policies and procedures are stored. On a project specific basis, the Partner-in-Charge, Project Manager and project team review the quality measures necessary for implementation of the project. At the onset of each major task, the objectives, schedule, budget, deliverables, health and safety, and quality issues are defined in one of two ways:

1. a project/task plan, or briefing, is prepared and disseminated among the personnel involved; and/or

2. participation at a project/task kick-off meeting for which these items are conveyed.

Subsequent to the communication of these issues, the respective Task Leaders and Project Manager will implement the proper quality procedures and coordinate with the Partner-in-Charge and QA Manager or his/her designated quality person, accordingly.

2.7 DISPUTE RESOLUTION

In the event that personnel do not concur regarding technical matters, QA/QC requirements and approaches, services and product requirements, arbitration will commence at the lowest level of management; i.e., Task Leader and Project Manager. The parties will attempt to resolve their differences through meetings and discussion, but in no case will the final resolution compromise the basic tenets of quality established by this QMP. If resolution is not reached, the Partner-in-Charge will become involved to facilitate the situation and resolve the matter in conjunction with the QA Manager or his/her designated quality person.


3.0 QUALITY SYSTEM COMPONENTS

The purpose of this section is to document how ERM manages its quality system, including responsibilities for implementing quality system components.

3.1 IDENTIFICATION OF QUALITY SYSTEM COMPONENTS

The major components of ERM’s quality system include:

Project planning;

Management of change;

Personnel training and reviews;

Data management and data quality assessments; and

Quality documentation.

3.1.1 Project Planning

Project planning is key to good project management. The Partner-in-Charge and Project Manager orchestrate project planning.

Development of a Work Plan

At the start of a project, the Project Manager develops a work plan that outlines the use of resources to complete each task, including QA processes. This work plan is sometimes prepared during the development of the project proposal. The work plan presents each task, staff responsibilities, budget and schedule. Project work plans are reviewed and approved by the Partner-in-Charge.

The work plan is reviewed during the project kick-off meeting.

Copies of the project kick-off meeting notes should be placed in the project file. Following the project kick-off meeting, routine communications and project/task meetings are conducted to review progress, technical issues, quality assessments, schedule and budget.


Health and Safety

Health and safety planning is conducted prior to commencement of project activities. ERM has implemented a comprehensive health and safety program designed to foster a positive safety culture with ERM employees and subcontractors, and to control and reduce the likelihood of work-related accidents. The program is guided by a uniform policy, driven by standards, and incorporates Occupational Health and Safety Assessment Series (OHSAS) 18001-based elements. Rounded out by the ERM Behavior-Based safety program (You See It, You Own It), it emphasizes risk assessment and control, strong communications, training, self-assessment, electronic tools, and continuous improvement.

An introduction and overview of ERM’s approach to health and safety is available within the ERM Global H&S database. All employees must familiarize themselves with the H&S information and requirements and undergo both ERM-specific health and safety training, as well as, OSHA required training prior to performing field work.

Work Activity Risk Assessment (WARN)

The ERM WARN process is a screening-level hazard assessment process that assists ERM employees in determining the proper level of health and safety planning necessary for each project. An electronic tool has been developed to assist ERM employees perform safety planning through the WARN process in a similar way each time. The electronic WARN Planning Assistant is a three step process whereby the proper health and safety plan (HASP) is selected, pertinent job hazard analyses are identified, and any client-specific health and safety requirements are integrated.

WARN provides additional focus and guidance for historically high-risk activities. For example, intrusive activities receive special attention under ERM’s Subsurface Clearance (SSC) guidance. SSC guidance is based on the best practices of some of ERM’s most sophisticated clients and the knowledge of numerous ERM remediation practitioners. Travel to potentially dangerous locations – those that we call “Particularly Challenging Locations” – have their own set of supporting tools, training and support intelligence.

ERM’s Health and Safety Program requires the development of a project-specific HASP. The HASP establishes project-specific requirements for each site to protect the health and safety of personnel during all activities conducted at a site. The HASP will address the health and safety hazards


of each phase of project activities and will include the requirements and procedures for employee and subcontractor protection. It provides information to facilitate control of exposure to hazardous material or hazardous conditions and to educate staff so work may be conducted in a safe manner. The HASP will include applicable Safe Work Practices (SWPs) and Job Hazard Analyses (JHA). SWPs and JHAs set forth ERM’s guidelines and expectations for physical activities performed on site and help address the associated health and safety risks and regulatory requirements for those activities.

Subcontracts, Supplier Contracts and Inter-Company Agreements

ERM requires that any external subcontractor or supplier considered for a project be registered in ERM comprehensive contractor screening database and pre-approved before starting work (see Section 5.0 for the relevant procedures). All contracts and work authorization forms must be reviewed and signed off by the Partner-in-Charge. A copy of the contract/work authorization form will be held in the project file and the original submitted to Accounting.

After a subcontractor is authorized to perform the physical activities associated with the project work scope, they are often required to complete JHAs that outline their procedures for ensuring that their personnel are protected against the site hazards included in ERM’s HASP, and their work activities will conform to the requirements of ERM Safe Work Practices (SWPs) included in the HASP. JHAs will be reviewed by a H&S team member or Subject Matter Expert and will be included as an appendix to the HASP.

For any work conducted by a different operating company of ERM, an Inter-Company Agreement is prepared by the Project Manager that specifies the scope, schedule and budget for the work to be completed. This Agreement must be reviewed by the Partner-in-Charge, and accepted by the different ERM business unit.

3.1.2 Management of Change

To ensure that project changes are identified and managed accordingly, the Partner-in-Charge and Project Manager have discussions on a periodic basis to review the project progress, budget, and schedule.

Management of change is the responsibility of the Partner-in-Charge. Specifically, the Partner-in-Charge is ultimately responsible for additions to, or changes in, project budget, schedule, and resources.


3.1.3 Personnel Training and Reviews

ERM provides a range of training opportunities for staff to enable them to meet the needs of ERM clients and their own career aspirations. The particular training needs of individual staff members are identified formally by ERM as part of the annual review process. These needs are noted on each individual’s annual review records.

In addition, managers are required to maintain vigilance in identifying any particular training requirements during their frequent one-on-one meetings with their team members. A training budget is available each year for technical or non-technical training.

ERM also provides a range of other training opportunities for staff members throughout the year both internally through the ERM Academy and externally, as needed. The following training is required for ERM staff:

Training Course ERM Staff Required to

take course

Business Conduct and Ethics All

Avoiding and Preventing Insider Trading All

Anti-Bribery and Corruption (ABC) All

Preventing Harassment All

Health & Safety Orientation All

Project Management Fundamentals Selected staff

Project Management Excellence Selected staff

Additional Technical ERM training courses are held at regular intervals at various locations or over ERM’s intranet to ensure participation by appropriate staff. Courses are taught by both senior ERM professionals and outside instructors. Several examples of ERM’s staff training are summarized below. Additional formal courses include leadership training, key account management, time management, and risk management. ERM’s training program also includes extensive on-the-job training and coaching, including field procedures and formal reviews of work through project debriefings.


Training Category Description

Health & Safety 40-hour and 8-hour refresher training in compliance with 29 CFR 1910.120 and ERM’s Corporate Health and Safety Program.

First aid and CPR training. ERM’s Health and Safety Officer ensures only certified personnel work

at hazardous waste sites. Project Management Covers ERM-specific project management, communication, financial,

and scheduling requirements. Integrates EPA/OSHA “site manager” training concerning the

management of hazardous waste projects. Regulatory Compliance ERM methodology and approach for EHS auditing and ASTM Phase I

Environmental Assessments. Biweekly regulatory updates on changing environmental legislation and

its applicability to individual clients or facilities. Communications Technical writing classes.

Continual training regarding writing “tips”. Support staff attends quarterly in-house seminars to continually expand

skills. “Brownbag” Sessions Presentations by technical experts, including specialized remediation

technologies, new practice area capabilities to meet client needs, and Web-based data management.

Information sharing from ERM international offices, broadening staff knowledge of client challenges in the global marketing place.

Computer system, software, databases, and corporate formats. External Management Training/Courses (Representative)

University extension courses in management and finance. Sales training, contract negotiation. Specialized service industry courses in management and leadership

(e.g., Pathway to Principal). External Technical Courses/Conferences (Representative)

NGWA and Princeton Courses on Contaminant Fate and Transport, Aquifer Testing, Remediation Technologies, Natural Attenuation for Site Remediation, Groundwater Geochemistry.

Batelle Symposium on In Situ and On-Site Bioremediation and Conference on Remediation of Chlorinated and Recalcitrant Compounds.

In addition, ERM provides training at the “ERM Academy”. The ERM Academy is a robust program and vehicle through which all global training is conceived, developed and provided. The Academy’s online portal is reflective of ERM commitment to provide greater resources aimed at helping ERM staff grow and deliver to their fullest potential. The ERM Academy team, consisting of the Dean of the Academy and Global Director of Learning and Development and support staff, routinely add, develop, review, and improve ERM content offerings to ensure the program remains responsive to ERM learning and development needs as ERM grows and develops as a company. Courses are categorized as: ERM Way, Consulting Skills, Management & Leadership, Technical Expertise, and Performance Assurance & Risk.

Human Resources (HR) maintains records of all training provided to ERM staff. Personnel training specific to projects is the responsibility of the


Partner-in-Charge. Specifically, the Partner-in-Charge ensures that project staff are trained to perform their assigned roles in a manner compliant with project quality objectives.

3.1.4 Data Management, Data Quality Assessments, and Documentation

The QA Manager has responsibility over data management and data quality assessments. Data storage, tabulation, and assessment activities are completed by staff resources, as are routine QC checks for calculations and data transfer operations. The QA Manager oversees these QC checks and independently verifies that appropriate QC measures have been undertaken.

Furthermore, the QA Manager has overall responsibility for ensuring that QA/QC processes are documented for future use.

3.2 QUALITY SYSTEM TOOLS

ERM’s tools for implementing the above-referenced quality system components include:

This QMP;

Project-specific Quality Assurance Project Plan (QAPP), which will be prepared in accordance with the EPA documents EPA Requirements for QAPPs (EPA/240/B-01/003, March 2001; also referred to herein as QA/R-5) and Uniform Federal Policy for Quality Assurance Project Plan (EPA, March 2005; also referred to herein as UFP-QAPP);

Project Kick-off Meetings (in which project QA procedures are communicated);

Project work plans;

Partner-in-Charge and Project Manager communications; and

Quality training (including communication of data management protocol).


4.0 PERSONNEL QUALIFICATION AND TRAINING

The purpose of this section is to document the procedures in place to ensure that personnel performing work for the project have the requisite skills.

4.1 TRAINING POLICY

It is ERM’s policy to provide its management and staff with training so that they can effectively execute their project responsibilities. This training encompasses all staff and includes, at a minimum, technical training, health and safety training, and (as applicable) project management training (see Section 3.1.3).

ERM’s technical personnel have experience on a variety of projects directed by various partners of the firm. To the extent practical, each member of the technical staff has been cross-trained in more than one area of expertise. This enhances their benefit to a variety of projects as well as their ability to provide timely and relevant support to dynamic project activities. Each professional employee is provided with training in project management, ERM’s systems and controls, continuing education in technical areas of expertise, and leadership.

In addition to internal training, ERM provides its employees with a tuition reimbursement program, which covers all or a substantial portion of college and/or postgraduate course fees upon satisfactory completion. ERM also sponsors employees to attend seminars and training programs that will increase knowledge and/or further competence in their professional practice areas.

Professional staff is encouraged to participate in professional associations (e.g., ASChE, AWMA, ACS, AIHA, and NGWA); many are active in regional/national activities of these groups. ERM has also instituted incentive programs to encourage professional registration and certifications, and presentation of technical papers at conferences.

The particular training needs of individual staff members are identified formally by ERM as part of the annual review process. Both the staff and supervisors participate in the preparation of a professional development plan each year. Professional development goals and specific training are discussed at this time. Follow-up activities are conducted to ensure that


training is addressed to satisfy the individual’s development plan requirements.

4.2 TRAINING PROGRAM MANAGEMENT

ERM assigns certain company officers as training directors to oversee and direct its training program. The training directors assign training instructors, internal or external, to administer training to ERM personnel. Both training directors and trainers are required to have successfully completed an instructional program (train-the-trainer) and/or have the academic credentials/certifications and instructional experience necessary to teach their specific course or program These qualified training directors, with the help of support staff, maintain records of training for company staff, and coordinate routine training programs to ensure that staff are trained in a timely fashion following the onset of employment and maintain compliance with appropriate training requirements for potentially hazardous site activities. Specific training elements are required on a periodic basis; whereas, other staff development opportunities are identified based on project needs, staff requests, and/or company preferences.

External training is also available to ERM employees. Classes, seminars, conferences, and other opportunities for professional development are encouraged and identified during the annual review process. External training relies on other professional trainers and experts to educate and/or train staff. Additionally, the ERM Academy is available to all staff to supplement other internal and external training. The ERM Academy hosts numerous educational, training, and refresher opportunities.

In addition, Project Managers are required to maintain vigilance in identifying any particular training requirements during their frequent one-on-one meetings with their team members as well as during the annual review process. Where training needs are identified, follow-up activities must be taken to ensure that those needs are addressed adequately within the specified timeframe. In cases where specific training has been provided for the development of individuals, evaluation must be undertaken to assess the effectiveness of the training in terms of the individual’s personal development and its relation to the needs of ERM’s business. Human resources would liaise with the appropriate team leader (i.e., Project Manager) in this respect and ensure that details are recorded on the individual’s personnel file.


For engineering projects, the Partner-in-Charge ensures that the projects are staffed with Registered Professional Engineer(s) and Registered Professional Geologist(s) with specific expertise in the applicable fields of interest. Similarly, for other specialized areas (e.g., wetland habitat creation, heavy equipment operation), the Partner-in-Charge ensures that sufficient resources are assigned to the project or, as necessary, that appropriate subcontractors are utilized to complete these specialized steps.

Training directors, the Partner-in-Charge, and the Project Manager have the authority to require specific training for ERM personnel to ensure that each ERM employee is adequately trained to perform their duties/job functions in a safe manner and without risk to their health and safety and that of others including contractors, visitors and members of the public.


5.0 PROCUREMENT OF ITEMS AND SERVICES

The purpose of this section is to document the procedures for procurement of items and services that can affect the quality of environmental project activities. For the Project Plans, it is envisioned that this component would be limited to subcontractor procurement.

5.1 ROLES, RESPONSIBILITIES AND AUTHORITIES

The Project Manager oversees subcontract procurement and management of materials and project-related services. As discussed in Section 5.2 below, all subcontractors must first meet ERM’s criteria to be available for consideration. The selection of a particular vendor is determined by comparing each response, item by item, to the scope of services and to the activity-specific evaluation criteria issued with the procurement for products or services. Any deliverable that does not meet the specification outlined in the scope of services is deemed unacceptable, rejected immediately, and returned with the appropriate documentation for corrective action and re-submittal until the deliverable meets the requirements as outlined in the scope of services. If the final deliverable does not meet the required specifications as outlined in the respective scope of services, documentation detailing the rationale for non-compliance is forwarded to the Project Manager. The vendor thereafter receives notification from the Project Manager or QA Manager that they have failed to deliver the agreed-upon goods and services, and the appropriate contractual actions are initiated.

Technical reviews of the quality of services are conducted on a routine and continuous basis. These reviews draw upon the technical expertise of the Project Manager and the QA Manager or her designated qualified person to assess the completeness, accuracy, timeliness and overall quality of services being provided. The review will be conducted by the manager who has the expertise to critically examine the work that is being performed. As an example, the QA Manager for data management will assure that the data evaluated includes documents, activities, and laboratory data, and will perform quality assurance reviews to verify that the analytical laboratory QC Manager has completed a review to validate the data for correctness, adequacy, completeness, and assurance that the data quality objectives (DQOs) have been met.


Procurement records and files will be maintained for each project-related procurement action. Scope of services responses and selected vendors are maintained in the project file. Any changes to procurement documents through addenda or change orders undergo a review by the Project Manager or their designee to ensure adherence to project objectives. Decisions for modification of the procurement documents will be made by the Project Manager in concert and Partner-in-Charge

The examination of deliverables for acceptability is the responsibility of the Partner-in-Charge, as delegated to the QA Manager or his/her designated qualified person. Deliverables are examined when received on a continuous basis by appropriate project team members and issued only after a consensus is reached on the final product, which must meet all of the project quality objectives.

5.2 METHODS FOR QUALIFYING SUBCONTRACTORS

ERM maintains a stringent Subcontractor Management Program that applies to all ERM vendors as well as competitive bidding situations where ERM is providing bid solicitation services on behalf of project sponsors. The Subcontractor Management Program is administered by Avetta, a global company that qualifies and maintains updated information about suppliers and subcontractors based on ERM’s requirements. In order to work for ERM, all subcontractors and suppliers must be qualified under the Avetta system. As part of their service, Avetta gathers and maintains a host of information annually about ERM subcontractors and suppliers, including insurance limits, OSHA logs, safety performance and metrics, safety and training programs, bonding capability, and diversity information on a regular basis. In addition, they ensure that contractors agree to adhere to all of ERM policies including Anti-Bribery and Corruption (ABC) and Business Conduct and Ethics. By requiring all of ERM contractors and suppliers be qualified through Avetta, ERM streamlines ERM management and communication process regarding subcontractors, reduces ERM overall risks, shares information across a common database, and increases ERM ability to meet ERM client’s needs on a global basis.

ERM's minimum safety criteria are as follows:

No fatalities in the past 5 years;

A Total Recordable Incidence Rate (TRIR) at or below the industry average for the past 3 years based on NAICS code;


A lost/restricted rate (DART - Days Away, Restricted or Transferred) at or below the industry average for the past 3 years based on North American Industrial Classification System (NAICS) code;

Experience Modification Rate (EMR) at or below 1.0 for the past 3 years; and

No open regulatory citations or willful OSHA citations received within the past 3 years.

The prequalification status of each subcontractor or supplier is posted on the Avetta website once the subcontractor or supplier has completed the registration process. At the completion of the registration and evaluation, a subcontractor/supplier’s record in the system will be flagged based on the results of their evaluation. Green flags are given to contractors who have submitted all of the required documentation, and who meet ERM’s minimum standards for safety, insurance, and ethics. The pre-approved (“green flagged”) subcontractors can be considered for project work. Amber flags and red flags are issued to subcontractors who have not completed the Avetta registration process or do not meet ERM’s standards. These contractors are not eligible for consideration on a project.

In unique circumstances, a subcontractor or supplier that is not green flagged could request a variance to be considered for project work. The Chief Operating Officer, in consultation with other staff, can issue a variance for special circumstances, including historical safety incident rates, insurance limits, or other issues on a case-by-case basis. A copy of ERM’s Variance Request Flowchart is included as Appendix C.

ERM typically develops a preliminary list of potential prequalified subcontractors and submits a pre-qualification package to evaluate the candidate’s technical strength performance, and experience performing similar services at other sites.

For certain projects, ERM will require QAPPs and/or QMPs from subcontractors/suppliers. Generally, QAPPs and/or QMPs will be required from subcontractors/suppliers if pertinent information regarding services or supplies is required to supplement a project-specific QAPP. It is the responsibility of the QA Manager to request, review, and approve subcontractors’/suppliers’ quality related documentation, including, but not limited to, QAPPs and QMPs. The QA Manager will


ensure that all quality related documentation complies with ERM’s policy and any client-specific policies.

Once a subcontract is let, ERM reviews the subcontractor’s health and safety performance indicators and insurance coverage annually, ensures that contractors name project parties as additional insured’s, and requires training records for all site workers to ensure they maintain certifications relevant to their work assignments.

5.3 REVIEW PROCESS FOR SERVICES AND EQUIPMENT

The Project Manager and staff will be responsible for the identification and evaluation of the need for services and equipment. Requirements and specifications will be documented and then included or referenced in procurement documents. The acceptability of purchased items and services will be verified and documented by the Project Manager.

To ensure the accuracy and completeness of contracts and agreements, ERM uses guidelines such as:

Utilizing prescreened and prequalified subcontractors and only awarding contracts to responsible subcontractors that have demonstrated the ability to fulfill the associated technical and quality requirements of the proposed procurement;

Reviewing proposed procurements to avoid the purchase of unnecessary or duplicate items; and

Maintaining records detailing:

o Method of payment o Subcontractor selection o Basis for the contract price o Adequacy of products and performance

5.3.1 Review and Approval Process for Responses to Solicitations

If the Project Manager determines a need to procure a service, a Scope of Work will be developed by the Project Manager and incorporated into a solicitation request (e.g., Request for Bid, Request for Proposal, Request for Qualifications, or Purchase Order). All responses to solicitations will be thoroughly reviewed to ensure that provider meets the requirements of the Scope of Work.


A Work Authorization Form (ERM North America’s agreement/contract) must be prepared by the Project Manager, reviewed and signed by the Partner-in-Charge, and then issued to the subcontractor for signature. The subcontractor must agree to the ERM’s General Terms and Conditions (posted on ERM.com). The subcontract portion of the ERM.com website also contains certain ERM policies that apply to all subcontractors. In addition, depending on the type of work described in the Work Authorization Form, certain Special Terms and Conditions may apply. The Special Terms that apply are selected on the Work Authorization Form and are included on the ERM.com website for the subcontractor to review directly. A copy of the signed Work Authorization Form must be retained in the project file.

The Project Manager is ultimately responsible for the process of purchasing equipment, supplies, or services in a manner that will ensure that quality products or services are secured. The Partner-in-Charge will review and approve all final contracts.

5.3.2 Routine Analytical Services

Routine laboratory analyses may be conducted to sampling activities. The selected laboratory will be certified under the National Environmental Laboratory Accreditation Program (NELAP) and, if required, by the State Health Department. When applicable, samples will be analyzed by standard methods such as those published by the U.S. Environmental Protection Agency, the American Public Health Association, the American Society for Testing and Materials, and the National Institute for Occupational Safety and Health. If a sample analysis does not meet the minimum QC requirements, it must be re-analyzed, or if re-analysis is not possible due to holding time issues, re-sampling will be performed.

Laboratories under consideration are required to submit information on the types of analytical procedures performed, the methods used to perform each analysis, and their current QMP.

5.3.3 Special Analytical Services

Special analytical services include those laboratory methods that are not routinely performed by the production laboratories or require specialized methods or equipment. Grain size analyses and metals speciation are examples of special analytical services that may be required to characterize sediment or water samples. The Project Manager identifying the need for special analytical services will follow the same general


procurement process outlined above except the laboratory does not have to hold NELAP certification.

5.3.4 Equipment

Environmental measurement activities typically require the use of equipment, such as groundwater sampling pumps or field monitoring devices. Technical staff will specify equipment needs and work with vendors to ensure that the equipment meets requirements described in the Quality Assurance Project Plan and Field Sampling Plan.

All instruments and/or equipment used by ERM and/or ERM subcontractors on ERM project work must be properly maintained, controlled, calibrated and/or certified as necessary. Where appropriate, copies of calibration certificates and service records are requested at the time of the equipment rental or hiring of subcontractor and kept for reference in the project file.

5.3.5 Other Services

Drilling, surveying, geophysical surveys, and treatability testing are examples of other services that may require procurement during the course of a project. The Project Manager will ensure that the methods and review processes described above will be undertaken during the procurement of these services.


6.0 DOCUMENTS AND RECORDS

The purpose of this section is to describe the procedure for maintaining controls for quality-related documents and records for the project.

6.1 PROJECT CONTROL REQUIREMENTS AND IMPROVEMENTS

ERM uses quality controls and feedback during project implementation to help ensure that all data or information collected are of the quality necessary to comply with applicable regulations. During the project Kick-off Meeting, the Partner-in-Charge coordinates a discussion to identify quality-related documents that will be deemed as controlled documents for the purpose of the project.

6.2 DOCUMENT DATA MANAGEMENT

Office data is managed primarily in electronic format using a network platform and staff access nodes. All network users typically share information with team members through e-mail, server based document storage and retrieval, and document database links that allow access to the documents and data to the various team members. This system facilitates single file document management, eliminating multiple node-specific copies, and provides centralized daily backup and retrieval.

The following standard software packages are available for use by ERM personnel on this project:

Full Microsoft Office software package, including Word, Excel, Access, PowerPoint, and Project;

Adobe Acrobat;

Internet Explorer;

AutoCAD;

ArcView, and Map Info GIS capabilities; and

Microsoft Outlook.


Additionally, personnel have Internet access to the full EPA web sites and downloadable regulations.

ERM uses a variety of commercially available data management software packages to handle environmental project requirements. A relational database program could be used on a project to serve as a repository for all facility electronic data, both historical and newly generated data. In conjunction, ERM has an integrated GIS system that can be employed for spatial analysis. A GIS or CAD application can be used to overlay site information with graphical layers such as aerial photographs, topography, and analytical data. Additionally, GIS or other visualization software (e.g., EVS) output can be used for 3-D spatial analysis and presentation which may be important in documenting closure of the environmental issues at a site.

The database and data handling protocol will require data quality issues to be detected early in the project. ERM has database formats on file with several major analytical laboratory chains that allow quick input and evaluation. ERM has developed quality and quantity filters that are run at the time of electronic data deliverable (EDD) receipt. Additionally, individual databases can be established for various forms of project data, including documents and deliverables. It is ERM’s intent to utilize the inspection forms for certification reports, where applicable, to accelerate the reporting process.

The goal of ERM’s approach to data management is to create a secure environment, maximize data functionality, and have it readily available to all members of the project team. The format of any information shared with the project team members will be flexible and could be formatted to fit most any software.

Database protocols include security functions that minimize the potential for loss due to accidents and mechanical failures. All database information is backed up nightly as part of ERM data security plan implementation. Copies of the files are stored in a secure location, off site to facilitate system recovery, should it ever be necessary.

6.3 FIELD DATA MANAGEMENT

When field activities are initiated, all field activities, decisions, dimensions, site personnel, and any information pertinent to the fieldwork are documented in field log books. The information is recorded in a manner that would allow an uninformed party to reconstruct the


activities in the absence of the person who logged the activities. The Project Manager will review the field logs on a regular basis to ensure that the field tasks are executed according to approved work plans and to review and modify procedures, if needed, on a continuing basis.

Laboratory analytical data is typically transmitted via electronic formats that have been previously established with ERM subcontract laboratories. When data are tabulated, a peer review is conducted to ensure that the data were entered correctly from hard copies, the comparison criteria (e.g., detection limits, Maximum Contaminant Levels, etc.) were entered at the correct value for the correct constituent, and the exceedances were correctly identified.

6.4 DOCUMENT PREPARATION AND CONTROL

As a consultancy, ERM provides its clients with advice. This advice is normally provided in the form of one of more reports, but can be provided in other forms, such as a presentation or training course. The following applies to all project outputs, but refers only to reports for simplicity.

ERM’s approach to developing reports is to conduct a kickoff meeting prior to preparation. The primary purpose of the kickoff meeting is to discuss objectives, report/closure goals, assign tasks, and communicate schedule and cost constraints, if any. The Project Manager or task leader will then work closely with the staff for a short period of time to prepare a report outline, define tabulation structure, and prepare draft documents. The bulk of the draft deliverable is then prepared by the staff using the task leaders and Project Manager on an as needed basis to steer the report development in accordance with the goals of the project.

Depending on the nature and complexity of the reports, periodic team meetings or brainstorming sessions may be held during the preparation of the reports to discuss key elements and reach consensus on important issues.

Once an initial draft is completed, the Project Manager reviews the document for accuracy and appropriateness to the closure, including all text, tables, and drawings. Revisions and review comments are then discussed with the staff so that methodologies are communicated and the basis for the revisions is fully understood. In the case of a complex report, more than one preparation and review cycle may be necessary before the deliverable is ready for final review by the Partner-in-Charge and/or


certifying engineer/geologist. See Section 6.5 for a more detailed discussion of ERM’s document review and revision process.

Production of the final deliverable is coordinated between the technical staff that works closely with support staff to ensure the deliverable is accurately reproduced by the required deadline. After reproduction of the deliverable is complete, the original documents are compared page by page (or drawing copy) with every copy that has been produced to ensure that pagination is correct and no pages or inserts are missing or duplicated.

The support staff then prepares shipping packages once all copies are proofed. Shipping packages are not sealed until the Project Manager or task leader has checked that the shipping package includes the appropriate documents, the correct number of copies, and is addressed to the correct receiving party.

The Project Manager is responsible for ensuring that all versions of any deliverable sent to a client are saved on the appropriate ERM File Server and/or the project management file. Electronic versions of deliverables sent to clients are stored in the numbered project folder on the appropriate file server.

6.5 DOCUMENT REVIEW & REVISION

It is the ERM policy that all major project deliverables generated throughout the course of the project must be reviewed by the Project Manager and the Principal-in-Charge. It is the role of the Project Manager to assure that such peer reviews are conducted for each project. Evidence that deliverables have been reviewed must be available on the project file. This will normally be in the form of the electronically reviewed report, using Microsoft Word track-changes and comments, and emails requesting the review.

Also, additional QA/QC elements could be established that not only conforms to the ERM Management System described above, but also contains three subordinate elements within the Senior Level Reviews:

Activity or Deliverable Review. Utilize senior staff to evaluate technical soundness and execution, compliance with regulatory requirements, and overall presentation;


“Red-team” Review. Performed by senior staff and strategic resources at particular stages of the project to identify obstacles, conflicts, and issues associated with the “big picture”, including redevelopment, community interests, real estate market drivers, planning and permitting authorities, financial incentives, infrastructure, and environmental interests; and

Project reviews. Performed at particular milestones to evaluate technical performance, cost effectiveness, reliability, quality, and risk management.

During the review, the reviewers will revise deliverables, as needed, and submit any revisions to the Project Manager for review and approval. Revisions to text are made using Microsoft Word track-changes.

6.6 DOCUMENT APPROVAL

All final deliverables must be reviewed and approved by the Partner-in-Charge or his/her designee. Final deliverable approvals are mandatory, and must be kept as a record in the project file.

6.7 DOCUMENT TRANSMITTAL

All transmittal documents will be complete prior to submittal. Complete submittal documents include signed and dated cover letter(s) as well as the entire document with all attachments or addendums. All electronic deliverables/external transmittals will be sent in either Adobe Portable Document Format (PDF) or other suitable format. Hard copies will be transmitted via United States Postal Service (USPS), FedEx, UPS, or other package delivery company and issued a tracking number. As necessary, the Project Manager will notify the recipient of the hard copy transmittal and include the tracking number and expected delivery date.

6.8 DOCUMENT DISTRIBUTION

The Project Manager is responsible for ensuring that all internally issued documents are readily available to the project team. The Project Manager will notify all personnel within the project team via email of document updates and will maintain a copy of the notification. It is the responsibility of the individual to ensure that all hard and/or electronic copies of documents in their possession are the most recent version.


The Project Manager will ensure that all obsolete documents or older versions of revised documents are protected from unintentional use by segregating or disposing of obsolete documents. Any obsolete documents that are kept for reference or other purposes will be clearly identified through markings, separate storage areas, or other means. The Project Manager will advise the project team to dispose of electronic and hard copies of the obsolete documents via email and maintain a copy of the notification.

6.9 RETENTION

ERM will, as necessary, prepare formal project documentation in compliance with project requirements. This will include documentation of work performed and feedback on the quality processes in place to help ensure that the data being collected for this project are in compliance with the applicable regulations.

Hard and/or electronic copies of the following documents must be maintained in the project paper files and/or electronic folder:

A copy of the signed contract and all amendments, addendums, and change orders;

Copies of final versions of all reports/outputs;

Copies of all incoming and outgoing correspondence;

Copies of project data (laboratory reports, etc.); and

Working papers as appropriate. These include field logs, sketches, notes, records, office calculations, final drafted figures (not interim drafting), emails at Project Manager discretion, voicemails transcribed at Project Manager discretion, internal memoranda, contracts, work assignments, scopes, budgets, invoices, timesheet backup, vendor invoices, expense reports, etc.

Each ERM project has an electronic folder. These are housed on an ERM company-wide server, which is password restricted. Servers in each project office are backed up each weekday to tape or an offsite server. These backups are retained for one year.


ERM’s Document Retention Policy is to maintain relevant project documentation per the client contract or regulatory agency, or for a period of at least five years from the completion of the project. ERM documents are maintained and stored in the following ways:

Retained in hardcopy and/or electronic form in project file;

Stored as electronic files as .pdf/Word/Excel on file server;

Retained in off-site archives after project closes; and

Project files are discarded according to the contract requirements.

It is the responsibility of the Information Technology (IT) Officer or designated staff to:

Work with the ERM Group IT function to maintain the integrity of the IT system such that electronic project files are secure and available to staff at all times;

Ensure that project and proposal management files are appropriately set up on the office servers;

Ensure that backup procedures are strictly followed and backup tapes are safely stored such that key information is never lost; and

Work with the ERM Group IT function to develop appropriate storage facilities so that project files can be retained and be readily retrieved according to contract requirements.

The aim is to protect the data stored on the office file servers from disk crash or malfunction on a daily basis (i.e., only part of a day’s files will be lost) and from more catastrophic fire or water damage on a weekly basis (weekly backup tapes are stored off site).

6.10 CONFIDENTIALITY

All ERM projects are treated confidentially. Each employee must agree to ERM’s Statement of Confidentiality, which includes the following terms and conditions:


1. You agree that you will not, during the term of your employment with ERM or at any time afterward, directly or indirectly: (1) reveal or disclose Confidential Information to any person or entity; or (b) make use of Confidential Information either for your own benefit or to the benefit of any other person or entity, without prior written consent of the Company.

2. In the event of termination of your employment with ERM for any reason, you agree to return to ERM, without taking or making copies, all documents pertaining to the business of the Company, regardless of whether such documents were prepared by you or were provided to you.

3. The validity and interpretation of this agreement shall be governed by the laws of your local ERM office.

However, if the client has requested specific confidentiality arrangements beyond those adopted as standard by ERM, then these must be identified and put in place.

It is the responsibility of the Partner-in-Charge to ensure the correct level of confidentiality is chosen when projects are entered into GMS (i.e., “Confidential” or “Strictly Confidential”), and to identify any specific confidentiality terms and conditions beyond those adopted as standard by ERM. The Partner-in-Charge will review the client contract/agreement for a confidentiality clause and have a discussion with the client to get understanding of what they want and expect. Any specific confidentiality arrangements must be recorded in a Confidentiality Arrangement, Non-Disclosure Agreement, Master Service Agreement, and/or in the project Terms & Conditions. A signed copy must be kept in the project file.

For Confidential or Strictly Confidential project, the Partner-in-Charge or Project Manager will prepare a written summary of project confidentiality requirements, including document labeling, handling, storage, and destruction procedures. The summary will be disseminated to the nominated team for review and signatures (if required). Nominated team members will also be provided with a copy of the Confidentiality Agreement, Non-Disclosure Agreement, or confidentiality provisions from the Master Service Agreement or the project Terms & Conditions prior to working on the project. Signed copies (if required) are to be maintained in the project file.


Access to confidential information will be limited to team members nominated by the Partner-in-Charge and provided on a need-to-know basis.

The Partner-in-Charge and Project Manager are responsible for ensuring that the following security requirements for strictly confidential projects are followed:

The project is to be provided with a code name.

The project and proposal electronic folders located on shared network drives are to have restricted access.

During the project, printed documents, project files, commercial files, reports, etc. are to be kept in secure project files (i.e., locked drawers). Only authorized individuals shall have routine access to this file cabinet. No materials will be left out overnight.

For physical file folders, labels for the project are to include “Strictly Confidential”.

Review the document destruction requirements of the Confidentiality Agreement, Non-Disclosure Agreement, or confidentiality provisions from the Master Service Agreement or the project Terms & Conditions at the conclusion of the project. Special end-of-project procedures (e.g., document destruction requirements) will be followed and documented. All project-related hard drive files should be purged onto the secure project folder on the network at the project’s end. Contractual requirements regarding physical file closure will be following, including shredding or confidential destruction of excess paper files.

6.11 CHAIN-OF-CUSTODY

Any environmental test sample collected will be properly documented on a chain-of-custody form to facilitate timely, correct, and complete analysis of data. The chain-of-custody form is used to identify, track, and monitor each sample from the point of collection through final data reporting and is necessary if there is any possibility that the analytical data or conclusions based upon analytical data will be used in litigation. Chain-of-custody documentation for environmental test samples is performed in accordance with mandated procedures provided by the EPA, and other


agencies regulating the shipment and transportation of samples. All details regarding chain-of-custody and chain-of-custody forms are provided in the project work plans or QAPP. Chain-of-Custody Forms are obtained from the EPA or from the laboratory performing the sample analysis. It is the role of the Project Manager or Task Leader to review all chain-of-custody documentation to identify omissions and/or errors prior to receipt of the samples at the laboratory. When analytical reports are received from the laboratories, the data are immediately reviewed for completeness.


7.0 COMPUTER HARDWARE AND SOFTWARE

The purpose of this section is to document how ERM ensures that computer hardware and software are sufficient to satisfy project objectives.

In the course of the development of the Project Plans, ERM anticipates that it potentially could utilize software for data management (e.g., database, GIS, or spreadsheet software), drawing production (e.g., computer-aided drafting software), and design simulation software (e.g., leachate models). As part of its quality system, ERM utilizes standard, industry-accepted software for these functions. Management and update of office production software (e.g., databases, spreadsheets) is the responsibility of ERM’s information technology support staff.

With respect to hardware, ERM supplies its employees with functional, up-to-date hardware. This hardware is supported by ERM’s information technology support group. ERM’s Group IT Director manages IT systems and services at the global Group level. All purchases and installation of hardware and software and access to the Internet and worldwide web are reviewed, approved and managed by the local IT Department. The IT support staff has the sole authority to install software onto company computers. ERM’s information technology (IT) support staff is responsible for the management and update of office production software (e.g., databases, spreadsheets). The specialized professionals utilizing this software are responsible for the management and update of specialized software (e.g., GIS, design simulation software). Any necessary future downloads to aid or update the software will also be completed by the IT support staff. Strict rules are applied to use of ERM IT systems and these are accessible in the ERM Employee Handbook. All staff is briefed on IT systems as part of their induction on joining ERM.

7.1 PURPOSE

In order to ensure the efficient and reliable interchange of information between ERM and the client, computer software and hardware must be standardized and use industry compatible applications. Further, for internal use, it must be selected, installed, evaluated, and maintained by the ERM IT department. The IT department has standardized on Dell Computer (Dell) hardware. Each approved computer has been thoroughly tested with the ERM approved software. By testing the


software and hardware together, the IT department can ensure the compatibility of the entire system; more specifically:

The safety of data by requiring up-to-date virus software and scan;

Rework reduction since each new application can build upon what has already been tested;

Reduction in the requirements to validate new software on a system; and

Reduction of the time and cost training since each application has the same approved software.

By using approved software and hardware, ERM can ensure that ERM’s client focus is maintained. Other hardware and software will be used if requested by a client or otherwise required by a specific project after being tested by the ERM IT department.

ERM also has a Global Recycling program with Dell. The ERM Computer Recycling Program aims to standardize ERM’s approach to the disposal and recycling of old computer hardware. ERM uses Dell’s Asset Resale & Recycling Services. The Dell program is available in the majority of countries in which ERM operates. In the few countries where it is not available, the IT team is working with local business units to ensure we use companies that offer a service of equal quality and assurance as the Dell program (moving to Dell as the service becomes available).

In Dell’s disposal and recycling program:

If the equipment is unable to be resold, it is recycled;

The recycling service provides ERMs with auditable reports on:

o erasing of data – increasingly important for security purposes; o location and type of equipment recycled and verification of

status;

Dell has created a globally consistent policy that includes rigorous audit protocols, using approved partners and equipment processors.



It is the role of the ERM IT department to maintain a standard for the ERM computer network. ERM operates as a global IT function providing strategy directives and implementation by IT Technical Leads across varying IT Functions. Technical Leads are supported by technical regional and local leads, with the objective is to provide a broad technical framework within which all ERM companies operate. This ensures consistency across all IT systems within the Group while also allowing a high degree of autonomy regarding implementation and local support. This falls across all IT functionality from hardware, networks, security, software and deployment to service management.

Group IT is functionally responsible for ERM’s IT strategy, for ensuring ERM has the right organization and individuals, and for designing an effective approach to implementing worldwide IT plans in each ERM company.

ERM’s IT structure is based on a small number of IT Leaders worldwide, that are typically also involved 50% or more in local or Regional IT Operations.

Technical Team Leaders - are responsible for implementing new services, consistent global technical solutions and establishing safeguards and support structures for global systems, working through key ERM experts and IT staff;

Regional IT Managers – are responsible for ensuring ERM companies in each Region deliver effective IT, implement Technical Team proposals and support Group IT objectives.

The IT department develops, installs, tests, maintains, controls, and documents computer software and hardware used in environmental and engineering programs to ensure that they meet the technical and quality requirements and directives from management. All computer software and hardware purchases are routed through the IT department in order to ensure they meet user requirements.

Requests for software procurement come through to ERM’s Service Desk where the software is investigated for compliance (legal) and compatibility (technical) on ERM machines. Once both are agreed, the software is installed on a test machine first, and after testing will then be installed on an allocated ERM Machine.


The Technical Team Leaders work closely to ensure technical initiatives are identified and are subsequently effective in each ERM company in order to:

Review technical services on going to introduce continual improvements;

Define the technical standards necessary to meet Group business objectives;

Plan, configure, test new systems prior to implementation;

Define consistent roll out methodologies (Gantt charts, checklists, etc.);

Safeguard the security and integrity of ERM global systems;

Coordinate specific technical projects (e.g., Blackberry, Active Directory etc.); and

Coordinate support of specific IT systems (e.g., inter-company mail routing, gateways, global directory updates).

Commercial software such as word processing, spreadsheet applications, presentation packages, and e-mail applied to projects must be either within the company list of supported software or meet a client’s specific request. In the case of unsupported software at the request of a client, ERM will obtain a copy of the software to test with the existing hardware and software currently utilized on the ERM approved list. Once the testing is complete, the IT department will purchase and load the software as needed to complete the project. Specialized software used for other purposes such as numerical and environmental modeling, design, geospatial information systems, or data visualization/analysis will be used in accordance with the developer’s guidance.

7.3 INFORMATION PROTECTION

All computers on the ERM network are required to be operating with adequate virus protection provided by the IT department. Regular scans and updates are performed automatically by the central anti-virus servers to maintain all ERM computers virus-free. All offices are protected by a company firewall. In addition, each notebook computer has a personal


firewall installed to protect them when they are used outside of the office network.

7.4 PROCESS FOR MANAGING COMPUTER HARDWARE AND SOFTWARE

Models are reviewed based on upgrades from ERM Vendors and are reviewed by the Global IT team with input from Regional IT leads. Once acceptance testing is completed by the IT community and core user groups, a standard “image” is created that automatically installs standard security, software and drivers on the machine.

Configuration and installation of new computer is done through Microsoft image creation methodologies. All ERM workstations are locked down to user rights to prevent non-compliant installation of software/hardware to ensure ERM machines remain standard.

Hardware is purchased by a small group of IT Leads from the Dell global portal, which has pre-selected standard hardware configuration. ERM Global IT also states that only hardware can be purchased by IT.

All software installations are recorded in a centralized asset management system/database which includes information such as machine asset number, license information (registration keys/type/number), and where applicable maintenance renewal. Any software that requires specialized configuration is documented and stored on a specified network location along with installation files (access for IT Staff only).


8.0 PLANNING

The purpose of this section is to document how individual data collection operations will be planned to ensure that the data collected are of sufficient and expected quality for their intended use.

8.1 PLANNING PROCESS

This QMP includes a description of ERM’s general planning process for data collection efforts. Detailed data collection information is included in project QAPPs.

For its data collection efforts, ERM’s process adheres to the Data Quality Objective (DQO) approach utilized by EPA. DQOs are based on the concept that different data uses may require different data quality. The five categories of data quality include:

DQO Level 1 - provides the lowest data quality but the most rapid results, and is used for purposes of site health and safety monitoring, and initial site characterization to define areas for further study.

DQO Level 2 - provides rapid results but better quality data. Analysis includes some on-site generated data.

DQO Level 3 - provides an intermediate level of data quality and may be used for site characterization, risk assessment, and engineering design development. Engineering analysis may include on-site laboratory generated data and standard commercial laboratory analyses without full Contractor Laboratory Program (CLP) documentation.

DQO Level 4 - provides the highest level of data quality for routine analyses and is used for purposes of risk assessment and engineering design. For analytical data, confirmation analyses at this level may require full CLP analytical procedures and documentation.

DQO Level 5 - similar to DQO Level 4 except that analyses require modification of existing methods or development of new methods.


The ERM Project Manager is responsible for ensuring that data collection efforts are compliant with any QAPP and Sampling and Analysis Plan. Project personnel document data collection activities in field log books and/or on data collection checklists. These log books and checklists are reviewed by the Project Manager upon completion of collection efforts to ensure that DQO adherence parameter values are acceptable.


Planning is essential in order to conduct an efficient and organized project. The Project Manager responsibilities in this regard include:

Determining detail, size, scope, and schedule of the project within the limits of the contract document;

Determining the manpower requirements, including: managers, scientists, engineers, administrative support, technicians, and draftspersons;

Expanding the general scope of services into a detailed plan of action that describes the objectives, tasks, budgets, schedule, and deliverables for each task;

Maintaining liaison with the QA Manager or his/her designated qualified person and determining the QA and QC procedures to be implemented on the project; and

Correcting any deficiencies or inaccuracies throughout the term of the project, if detected.

The QA staff, which includes the Partner-in-Charge, QA Manager, his/her designated qualified person, and other staff supporting QA activities is responsible for providing guidance and technical support for planning field activities, data collection, and evaluation.

8.3 PROJECT TEAMS

ERM uses a matrix-management approach for the assembly of project teams. Matrix management allows for the creation of a balanced, multi-disciplinary professional team representing areas of diverse expertise, such as an engineer, geologist, and chemist, which can directly meet the


technical needs of the project. By design, matrix-management allows ERM to both provide company memory continuity while also allowing the introduction of new talent and expertise, as needed, in an efficient and effective matter. Matrix management ensures that the most appropriate Project Manager, based on expertise, is selected for a given project, but also ensures that the Project Manager is supported by an appropriately skilled, multi-discipline team. Multi-disciplined teams are critical to ensuring that solutions reflect a balanced and objective approach between engineering, earth sciences and life sciences, and are not biased or pre-disposed toward a particular discipline or outcome.

8.4 QUALITY ASSURANCE

Quality assurance is a key component of the ERM Management System. The ERM Management System contains the following in-process QA steps to ensure high quality deliverables:

Periodic and systematic review of all significant input data such as laboratory reports, field notes, site information, background data, and subcontractor submittals;

Routine review of project budgets;

Documented team briefings detailing scope, schedule, and budget; and

Partner-in-Charge/QA Manager review of all significant deliverables to the client.

The process for evaluating and qualifying data collected for other purposes or from other sources will be completed on a project and task specific basis. Field data such as that collected from monitoring instruments (e.g., organic vapor analyzer, pH meter, etc.), soil boring logs, geophysical tools, etc. and unvalidated analytical data may be used for scoping or design purposes and guide the number and location of samples as well as sample analyses. Validated data may be used to supplement the project data set and used for a trend analysis or risk assessment where the sample locations can be verified and the data is not subject to temporal variations.


8.5 QAPPS

Prior to data collection efforts, a QAPP will be completed to document the following:

Objectives of the data collection effort;

Intended use of the data to be collected;

Plan (scope and schedule) for data collection activities;

Procedures (field and laboratory) to be utilized;

DQOs;

Performance criteria to be measured for data collection efforts; and

QC samples to be collected, if any, to assess quality performance criteria.

A QAPP establishes procedures to ensure the integrity of all samples and measurements and the validity of all analytical data generated during the RI process. The QAPP will be prepared to meet the requirements of UFP-QAPP. The QAPP is based on the EPA’s most recent guidance, EPA Requirements for Quality Assurance Project Plans (QA/R-5, March 2001, reissued May 2016), which addresses four major quality assurance/quality control elements, as follows:

Project management;

Measurement/data acquisition;

Assessment/oversight; and

Data validation and usability.

Based on the four elements described above, a QAPP defines the general approach to program and data quality management in as much detail as is applicable to the diverse activities to be completed at a site. The QAPP will:


Provide project background information and describe project management, including data quality objectives and documentation requirements;

Describe the overall requirements for data measurement and acquisition with respect to sampling, laboratory analytical methods (including instrumentation maintenance and calibration) and quality control requirements. This includes analytical detection limits, sample preservation requirements, specification of sample containers, and analytical holding times;

Prescribe the DQOs: quantitative and qualitative project-specific requirements that specify the quality of the environmental data required to support the decision-making process. This includes a discussion of precision, accuracy, representativeness, completeness, and comparability of the RI analytical data set;

Address assessment and oversight with respect to verifying conformance and rectifying non-conformance; and

Describe the data validation and usability requirements. The QAPP details the data validation procedures to be employed to ensure data usability. The data validation is performed by ERM in accordance with EPA protocols. Any suspect data is flagged accordingly, and is considered during the data evaluation process.

The preparation of the QAPP will be coordinated by the QA Manager. The QA Manager and supporting staff will review the QAPP objectives, required elements, and project specific criteria prior to preparing the document. The QAPP is reviewed and approved by the Partner-in-Charge. The QA Manager, field implementation task manager, and lead field technician(s) will review the requirements for implementation. Updates and/or revisions to the QAPP are discussed with the QA Manager and incorporated, accordingly. The QA Manager and/or the Partner-in-Charge will review and approve the revisions.


9.0 IMPLEMENTATION OF WORK PROCESSES

The purpose of this section is to document how work processes will be implemented to ensure that data are of sufficient quality for their intended use.

9.1 WORK PROCESS PROCEDURES

The Partner-in-Charge works with the Project Manager to identify those data collection activities that requir

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