QUALITY ASSURANCE FOR STORMWATER

1 QUALITY ASSURANCE FOR MUNICIPAL STORMWATER PROGRAMS Prepared by Indian Nations Council of Governments (INCOG) Environmental and Engineering Services Tulsa, Oklahoma Project 2, Task 204 FY-03 604(b) (C6-400000-43) July 2006 EXECUTIVE SUMMARY This document has been prepared for the technical and managerial staff of cities and counties that must implement a comprehensive water QUALITY protection program under the Phase II STORMWATER regulations or otherwise want to implement local water QUALITY improvement programs. The information in this document provides an overview of the various strategies that must be considered to ensure that all information and data generated under a STORMWATER protection program are useable, defensible and effective.

2 The intended audience for this document is staff and management persons of a city or county that have little to no experience with: water QUALITY standards, creating and operating a water QUALITY inspection and enforcement program, or the importance of data QUALITY . While there are a number of checklist items in the document that can be used in creating QUALITY ASSURANCE plans and inspection programs, this is not a complete guidance on preparing these. Rather, the intent is to introduce the beginning staff person to the importance of data QUALITY and to provide direction and resources for developing local data QUALITY and inspection programs.

3 Cities having industrial pretreatment programs or major POTWs will have the greatest advantage as they will already have staff who are familiar with data collection, laboratory and field testing, documenting and reporting results to meet discharge permit requirements, negotiating with responsible parties of potential pollutant sources, and addressing technical questions from citizens, managers, councils, vendors, consultants and regulatory agencies. However, most Phase II municipalities do not have pretreatment programs, and their STORMWATER staff are floodplain managers, building inspectors and city planners, all with limited knowledge of water QUALITY data issues.

4 This document should enable a municipal STORMWATER manager to decide upon what types of data QUALITY strategies are needed and what resources are available to achieve a successful QA program. Agencies such as ACOG, INCOG, EPA and ODEQ should be contacted for assistance and information about establishing an effective data QUALITY program. This guidance is intended to be a planning tool in developing a reliable QUALITY ASSURANCE program for STORMWATER . INCOG QUALITY ASSURANCE Guidance July 2006 iiTABLE OF CONTENTS Section Title Page I Introduction1 II What is QUALITY ASSURANCE / Why is QA Needed1 III To What Does QA Apply2 Field Data 2 Facility Inspection Data 3 Construction Site Inspections 3 Data and QA Program Management 4 Maintenance and Storage of Equipment 4 IV What QA Does OKR04 Require4 V Levels of QUALITY Assurance7 Basic Written QA Procedures 8 Standard Operating Procedures (SOPs)

5 9 Data QUALITY Objectives (DQOs) 10 QUALITY ASSURANCE Project Plan (QAPP) 13 QUALITY Management Plan (QMP) 16 VI Employee Training / Safety17 Employee Training 18 Field Safety 18 VII QUALITY ASSURANCE Administration19 Role of the QUALITY ASSURANCE Officer 19 Lab Services 19 Lab Contracts 20 VIII Field Measurements and Test Kits21 Field Test Kits 21 Field Measurements 22 Field Observations 24 IX Sample Collection and Processing25 Sample Integrity 25 Sample collection 26 Sample Preservation and Holding Times 27 Chain of Custody and Sample Transport 28

6 QA/QC Samples for Field and Lab 28 X QA Guidance and References30 XI Definitions and Terms31 Appendix A EPA Example of SOP for Collecting Water Samples 35 Appendix B List of Laboratories Certified by ODEQ 41 Appendix C Sample Forms for Inspections 45 INCOG QUALITY ASSURANCE Guidance July 2006 iii I. INTRODUCTION As Phase II STORMWATER programs begin in Oklahoma, many activities of cities and counties will require consideration of the ruggedness of the data and of the procedures that will be employed to collect, analyze, store and report information. Defensibility of data and information is frequently overlooked, and development and deployment of a good QUALITY ASSURANCE (QA) program is time-consuming and expensive.

7 QA works behind the scenes of a data-rich program, and it is essential for a data program to function efficiently. There are several levels of data collection and data management that require different QA attention. This QA guidance will help Phase II STORMWATER permittees establish an effective program and provide basic QA information. Cities already employ QA procedures, mostly in the testing and operation of their water and wastewater treatment plants. All Oklahoma Pollutant Discharge Elimination System (OPDES) discharge permits require certain types of records to be kept and certain types of approved analytical tests to be performed by a certified laboratory.

8 A city s water and wastewater treatment plants are periodically audited by the Permitting Authority (PA) which in Oklahoma is the Oklahoma Department of Environmental QUALITY (ODEQ). All of these considerations are part of the city s existing QA program. The Phase II STORMWATER program is yet another OPDES permit, one that requires collection of a wide variety of data for purposes ranging from simply recording the number of brochures distributed to chemical sampling data to be used for justifying enforcement actions and assessing penalties through administration or court.

9 EPA has established guidance for understanding, developing and using data QUALITY objectives (DQOs), QUALITY ASSURANCE project plans (QAPPs), QUALITY management plans (QMPs), and standard operating procedures (SOPs). These documents are required of any organization that performs environmental data collection using Federal water QUALITY grant funds. In such cases, EPA and ODEQ formally review and approve each QMP and QAPP document. However, for non-Federal funded environmental programs, the guidance is nonetheless valuable to establish a QA program having the same QA oversight and effectiveness.

10 Challenges to data QUALITY are defended by having a good QUALITY system . EPA receives many requests to review and approve QAPPs and QMPs, but they can only approve those related to EPA water QUALITY funded projects. Therefore, the QA procedures for Phase II STORMWATER programs cannot be formally approved by EPA. The QA procedures described in this INCOG guidance are intended to cover the full range of QA development, from implementing a simple, informal QA program to preparation of formal QA documents based upon EPA guidance. Each STORMWATER permittee should select the level of QA that is appropriate to the data QUALITY objectives.