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Page 2: QUALITY MANAGEMENT PLAN - Studespace...This document describes the Quality Management Plan (QMP) for the water quality sampling and data management activities conducted by the SWQB

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Page 3: QUALITY MANAGEMENT PLAN - Studespace...This document describes the Quality Management Plan (QMP) for the water quality sampling and data management activities conducted by the SWQB

QUALITY MANAGEMENT PLAN

FOR

WATER QUALITY MANAGEMENT PROGRAMS

Surface Water Quality Bureau New Mexico Environment Department

Scientific Laboratory Division New Mexico Health Department

November 26, 2003

Printed on Recycled Paper

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TABLE OF CONTENTS LIST OF FIGURES ....................................................................................................................II LIST OF ACRONYMS ..............................................................................................................II

1.0 MANAGEMENT AND ORGANIZATION........................................................... 1-1 1.1 NMED Policy on Quality Assurance..................................................................... 1-1 1.2 SWQB Organizational Structure ........................................................................... 1-2

1.2.1 Point Source Regulation Section ................................................................... 1-3 1.2.2 Watershed Protection Section........................................................................ 1-3 1.2.3 Monitoring and Assessment Section.............................................................. 1-4 1.2.4 Financial Section............................................................................................ 1-4 1.2.5 Outreach and Special Services Team............................................................. 1-5

2.0 QUALITY SYSTEM COMPONENTS.................................................................. 2-1 2.1 Documentation....................................................................................................... 2-1 2.2 Tools for Quality Assessment................................................................................ 2-2 2.3 Roles and Responsibilities ..................................................................................... 2-3

3.0 PERSONNEL QUALIFICATIONS AND TRAINING........................................ 3-1 4.0 PROCUREMENT OF ITEMS AND SERVICES................................................. 4-1 5.0 DOCUMENTS AND RECORDS ........................................................................... 5-1

5.1 Facility Inspection Reports and Discharge Monitoring Reports ........................... 5-1 5.2 Laboratory Analytical Data ................................................................................... 5-1 5.3 Field Notes and Photographs ................................................................................. 5-2 5.4 Equipment Calibration and Maintenance Reports ................................................. 5-2 5.5 Survey Summaries ................................................................................................. 5-3 5.6 TMDLs................................................................................................................... 5-3 5.7 Correspondence ..................................................................................................... 5-3 5.8 Quality Assurance Documents............................................................................... 5-3

6.0 COMPUTER HARDWARE AND SOFTWARE.................................................. 6-1 7.0 PLANNING .............................................................................................................. 7-1

7.1 Data Requirements................................................................................................. 7-1 7.1.1 Performance Criteria...................................................................................... 7-1 7.1.2 Study Design.................................................................................................. 7-1

7.2 Project Coordination .............................................................................................. 7-2 7.3 Documentation....................................................................................................... 7-2 7.4 Health and Safety................................................................................................... 7-2

8.0 IMPLEMENTATION OF WORK PROCESSES ................................................ 8-1 8.1 Planning and Technical Documents ...................................................................... 8-1 8.2 Sample Collection.................................................................................................. 8-1 8.3 Quality Assurance.................................................................................................. 8-3 8.4 Sample Submittal ................................................................................................... 8-3

9.0 QUALITY SYSTEM ASSESSMENT AND RESPONSE .................................... 9-1 9.1 Roles and Responsibilities ..................................................................................... 9-1 9.2 Corrective Actions ................................................................................................. 9-3 9.3 Technical Review .................................................................................................. 9-3

10.0 QUALITY IMPROVEMENT............................................................................... 10-1 10.1 Quality System Components................................................................................ 10-1

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10.2 Documentation for Quality Assurance ................................................................ 10-2 10.3 Quality Improvement Measures........................................................................... 10-3

11.0 REFERENCES....................................................................................................... 11-1

LIST OF FIGURES Figure 1.1: Current Organization of the Surface Water Quality Bureau .................................. 1-6 Figure 5.1 Quality Assurance Protocol, New Mexico Environment Department, Surface Water

Quality Bureau................................................................................................................... 5-5 Figure 5.2 Quality Assurance Checklist, New Mexico Environment Department, Surface Water

Quality Bureau................................................................................................................... 5-6

LIST OF ACRONYMS ADB Assessment Database BIOS Biogeographic Information Observation System BMP Best Management Practice BOD Biochemical Oxygen Demand CAFO Concentrated Animal Feeding Operation CD-R Compact Disc - Recordable CD-ROM Compact Disc - Read Only Memory CFR Code of Federal Regulations CPR Cardiopulmonary Resuscitation CWA Clean Water Act DOS Disc Operating System DPD N,N-diethyl-p-phenylenediamine DQO Data Quality Objective EDD Electronic Data Deliverable EPA U.S. Environmental Protection Agency GIS Geographic Information System ITS Information Technology Services MAS Monitoring and Assessment Section MF Membrane Filter ML Minimum Level of Quantitation mL Milliliter MPN Most Probable Number NERL National Exposure Research Laboratory NMAC New Mexico Administrative Code NMED New Mexico Environment Department NMHD New Mexico Health Department NPDES National Pollution Discharge Elimination System oC Degrees Celcius OSS Outreach and Special Services PC Personal Computer

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PQAP Proposal Quality Assurance Plan PSRS Point Source Regulation Section

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LIST OF ACRONYMS (CONTINUED) QA Quality Assurance QAPP Quality Assurance Project Plan QC Quality Control QMP Quality Management Plan SLD Scientific Laboratory Division SOP Standard Operating Procedure SPO State Personnel Office STORET Storage and Retrieval SWQB Surface Water Quality Bureau TMDL Total Maximum Daily Load TSS Total Suspended Solids WPS Watershed Protection Section WQCC Water Quality Control Commission WWTP Waste Water Treatment Plant

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1.0 MANAGEMENT AND ORGANIZATION

The Surface Water Quality Bureau (SWQB) of the New Mexico Environment Department (NMED) and the Scientific Laboratory Division (SLD) of the New Mexico Health Department (NMHD) are committed to good science and aggressive quality assurance (QA) practices. This commitment complements the U.S. Environmental Protection Agency’s (EPA’s) own emphasis given to a comprehensive and coordinated QA program. This document describes the Quality Management Plan (QMP) for the water quality sampling and data management activities conducted by the SWQB and the SLD. These activities include but are not limited to streams, lakes, playas, effluent discharges, National Pollution Discharge Elimination System (NPDES) permittee inspections and limited groundwater sampling. This document has been prepared in accordance with the EPA Requirements for Quality Management Plans (QA/R-2, EPA 2001a). Its objectives are to delineate the QA policy and management structure, which will ensure the validity of environmental measurement data. Further, this document ensures that all monitoring and measurement activities funded by the EPA will be conducted in accordance with EPA’s monitoring and QA requirements.

1.1 NMED Policy on Quality Assurance It is the policy of the NMED and the NMHD that there shall be sufficient QA activities conducted within the two departments to ensure that all environmental data generated and processed will be scientifically valid, of known precision and accuracy, of acceptable completeness, representativeness, comparability and, where appropriate, legally defensible. This goal can be achieved by ensuring that adequate QA steps and procedures are used throughout the entire monitoring process, from initial study planning through data usage. Each major, separate activity within the SWQB for which environmental data are generated, will develop a quality assurance project plan (QAPP) addressing the major elements contained in the EPA Requirements for Quality Assurance Project Plans (QA/R-5, EPA 2001b) and EPA Guidance for Quality Assurance Project Plans (QA/G-5, EPA 2002). Most sampling activities of the SWQB will be conducted under the “umbrella” document Quality Assurance Project Plan for Water Quality Management Programs (NMED/SWQB in progress). The use of this document ensures that environmental data generated by individual projects throughout the State will be comparable. Each major, separate activity within the SWQB for which environmental data are generated, will also develop a project-specific sampling plan, which includes the data quality objectives (DQOs) for the project. The intended use of the data will be defined in the sampling plan before the data collection effort begins, so that appropriate QA measures may be applied to ensure a level of data quality commensurate with the monitoring objectives. This sampling plan will address the major elements contained in the Guidance for the Data Quality Objectives Process (G-4, EPA 2000a) and will also document reasons for the selection of each sampling site. Each program will ensure that adequate resources are provided to support the QA effort and will also be responsible for implementing the plan.

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All environmental data generated will be of known quality. All data to be used for compliance determination will be of known and acceptable quality. The QA information developed along with all environmental data will be documented and available. The technical and administrative authority for all QA matters within SLD will be assigned to the Director of QA.

1.2 SWQB Organizational Structure The SWQB is comprised of five sections—the Watershed Protection Sections (WPSs) in Santa Fe, and Silver City, the Point Source Regulation Section (PSRS), the Monitoring and Assessment Section (MAS), the Outreach and Special Services (OSS) Team, and the Financial Section. The current organization of the SWQB, along with names and titles of incumbents, is given in Figure 1.1. The QA Officer for the SWQB reports directly to the Bureau Chief and has the primary responsibility for ensuring that all sections comply with the appropriate QA procedures. Responsibilities include preparing and updating the QMP and its dissemination to all SWQB personnel, review and approval of all SWQB QAPPs, review of all generated QA data and assessment of alternative methods and procedures. The QA Officer has the authority necessary to carry out the duties and can directly communicate with all SWQB staff and, through the Bureau Chief, to senior management. The Bureau Chief and the Program Managers of the SWQB and senior management will be kept informed about quality issues by means of periodic reports prepared by the QA Officer. QA reports prepared by the SLD Director of QA will also be distributed to SWQB personnel. This QMP covers all water quality and effluent discharge sampling activities, all watershed management activities and all water quality data management activities of the SWQB. Program managers of the three sections collecting data (WPS, MAS, and PSRS) are ultimately responsible for verifying that all activities of these sections comply with the provisions of this QMP and the appropriate QAPP and sampling plan. In each section the Project Leaders or Principal Investigators are delegated responsibility for verifying that all water quality and effluent sampling procedures, all watershed management activities, and all water quality data management activities comply with the provisions of this plan. Periodic checks of procedures and data management activities will be conducted by the Bureau Chief, the Program Managers, and the QA Officer. All changes to procedures and methods contained in this Plan and in the appropriate QAPPs must be subsequently accompanied by changes to and approval of the language of the plans themselves. The plans must be reviewed at least annually and updated if necessary. At a minimum, the approval page must be updated yearly with new signatures of all parties. This updating process is intended as an opportunity to review and evaluate the procedures and methods used and to consider alternative procedures and methods. The Bureau Chief, in collaboration with the Program Manager and staff of each section conducting water quality sampling efforts, will select the projects to be undertaken during the year in view of data requirements and resource availability. The Project Leader or Principal Investigator in collaboration with the Program Manager and assisting technical staff will develop sampling plans or sampling and inspection plans for each project. The Project Leaders and

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Principal Investigators are responsible for final sampling plans, implementation of data-gathering activities, review of field and analytical data and management of resultant data. All staff are encouraged to continually question and evaluate methods and procedures used and to initiate discussions on possible modifications. Data gathered by each section will be evaluated by the Program Manager and the QA Officer. The Bureau Chief, the program managers and the QA Office will assess the effectiveness of environmental programs. The SWQB carries out the activities associated with surface-water-related monitoring, surface water planning, development of total maximum daily loads (TMDLs), operator training and certification, effluent compliance sampling, and facility inspections required by the Water Quality Control Commission (WQCC) and EPA Region 6. Missions for the individual sections are discussed below.

1.2.1 Point Source Regulation Section This section is responsible for coordinating with EPA Region 6 on point source discharges under the Clean Water Act’s (CWA’s) NPDES permit program. Included is the review and certification of draft federal NPDES permits to ensure that State concerns and the Standards for Interstate and Intrastate Streams (NMAC 2002) are protected. This section conducts compliance inspections at federally permitted NPDES facilities. Sampling data from effluents and the receiving stream above and below the discharge location are entered into EPA’s Storage and Retrieval (STORET) database. The section also protects surface water quality through implementation of WQCC regulations dealing with unpermitted point source discharges and spills. The section assists EPA with stormwater, sludge permitting requirements and concentrated animal feeding operations (CAFOs). This section also administers the State’s program to certify operations and maintenance personnel at all public water and wastewater utilities, duties that were formerly addressed by a separate Facility Operations Section. These duties include the development and administration of certification exams, the processing of applications for certification and renewal, the tracking of certified operators’ continuing education courses, evaluation of training courses and the tracking of compliance with operator certification requirements. The PSRS section is also responsible for assisting in the certification of operators for all public water supply systems in the State and for providing information and directed technical assistance to New Mexico municipalities to help them prolong the useful life of the wastewater treatment facility and maintain compliance with federal and State regulations. Activities of the PSRS section are federally funded.

1.2.2 Watershed Protection Section The Santa Fe WPS provides a major component of the protection of New Mexico’s surface water resources. The section works cooperatively with local, State and federal agencies, interested organizations, and with private citizens to implement best management practices (BMPs) to reduce nonpoint source pollutants from entering surface and ground water resources of the State. The section issues grants to organizations wishing to design and implement nonpoint source pollution controls. Among the numerous projects being pursued by the section are streambank

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stabilization, mineral impacts remediation, road construction BMPs, and watershed protection. The section also conducts extensive public outreach activities including distribution of nonpoint source educational materials, training activities in the public schools and the publication of a quarterly newsletter. Activities of this section are federally funded. The Silver City team of the WPS provides most of the services offered by the WPS in Santa Fe for the southern portion of the State. This section also performs some of the duties of the MAS in the southern portion of the State, such as performing intensive water quality surveys. This section is administratively attached to the WPS in Santa Fe.

1.2.3 Monitoring and Assessment Section This section conducts stream and lake water quality surveys to determine whether or not New Mexico’s water quality standards are being met and designated uses are attained, and prepares technical reports detailing survey results. The results of these water quality surveys are used to develop necessary TMDLs for those surface waters listed on the State’s 303(d) list of waters not meeting standards. Many of these activities serve as screening processes to discover and document problems to be addressed by other SWQB sections. All analytical results obtained during these surveys, which meet applicable QA/quality control (QC) requirements, are stored on STORET, EPA’s computerized database for the storage and retrieval of water quality data. The section prepares retrievals for interested parties as requested. This section also conducts short-term investigations in response to emergencies and citizens’ complaints. The section also has commenced the task of determining levels of contaminants of concern in the edible flesh of fish tissue in the various State waters, with primary emphasis on the development of public fish-consumption advisories. When assistance is specifically requested, the section also conducts training activities for tribes and pueblos to assist them in the development of water quality standards and the environmental programs necessary to protect tribal waters. Activities of this section are federally funded. This section is also responsible for developing and maintaining the Section 303(d) list, which is a list of water quality limited segments, and developing TMDLs for point and nonpoint source discharges to these segments. The section also maintains the SWQB’s website, geographic information system (GIS) and database development. The section conducts watershed-planning efforts that reflect the federally mandated watershed-based approach to the protection of water quality.

1.2.4 Financial Section The Financial Section provides necessary services to the Bureau Chief and other sections in the Bureau. These services include the tracking of employee work hours, leave tracking, completing vouchers for purchases and for travel, preparation of contracts, preparation of grant applications, budget and grant tracking and information systems support. These services were formerly provided by several individuals in different sections.

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1.2.5 Outreach and Special Services Team The Outreach and Special Services (OSS) Team Leader reports directly to the Bureau Chief. The OSS Team performs bureau-wide support tasks in program enhancement, public access and project development. Team efforts include creating exhibits, newsletters, brochures and other materials for presentation and distribution in public forums. The team maintains and administers the public participation program, including providing the public with appropriate notice and information and conducting public meetings on various surface water quality issues such as TMDL development, water quality standards revisions, and other bureau activities. The team coordinates and maintains the bureau website and provides draft editing for certain WQCC documents including the CWA § 305(b) Report to the U.S. Congress (Water Quality and Water Pollution Control in New Mexico) and the State Standards for Interstate and Intrastate Streams (20.6.4 New Mexico Administrative Code [NMAC]).

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Figure 1.1: Current Organization of the Surface Water Quality Bureau

Marcy Leavitt Bureau Chief

Conservation Practices & Mining Act Team

Vacant Mining/Geo Eng

Biology & Geomorphology Team Shann Stringer Env Sci & Spec

Financial & Administration Section Ben Rael

Admin/Ops Manager

Point Source Regulation Section Glenn Saums Staff Manager

Watershed Protection Section David Hogge Staff Manager

Monitoring & Assessment Section Vacant

Staff Manager

Outreach & Special Services Team Vacant

Env Sci & Spec

Financial Team Margaret Rivera

Business Op Spec

Municipal Team Steve Baumgarn Env Sci & Spec

TMDL, GIS & Database Devl. TeamLynette Guevara Env Sci & Spec

Vacant Env Sci & Spec

Dolores Herrera Office/Admin Support

IndustrialTeam Richard Powell

Geosci

Gary King Env Sci & Spec

Julie Arvidson Env Sci & Spec

Lorenci Kaniatobe Financial Spec

Pauline Vigil Financial Spec

Sandy Spon Env Sci & Spec

Facility OpsTeam Mike Coffman Eng All Other

Bret Lucas Env Sci & Spec

Barbara Cooney Env Sci & Spec

Marie Ortiz Mgt Analyst

Violet Miera Office Clerk

Dennis QuintanaEnv Sci & Spec

Watershed, Wetlands & ImplementationTeam

Mike Coleman Geosci

Abraham FranklinEnv Sci & Spec

Delbert Trujillo Env Sci & Spec

Vacant Env Sci & Spec

Dan Guevara Env Sci & Spec

Allan Pasteris Geosci

Nina Wells Env Sci & Spec

Vacant Env Sci & Spec

Maryann McGraw Env Sci & Spec

Silver City Team

Mike Matush Line Manager

Dave Menzie Mining Geo Eng

Daniel Claypool Env Sci & Spec

Bessie Muzumdar Office/Admin Support

Cecil Severs Comp Sys Analyst

Bill Skinner Env Sci & Spec

Jennifer SandersEnv Sci & Spec

Water Chemistry Team Danny Davis

Env Sci & Spec

Scott Hopkins Env Sci & Spec

Doug Eib Env Sci & Spec

Neal Schaeffer Env Sci & Spec

Larry Smolka Eng All Other

Gary SchiffmillerEnv Sci & Spec

Seva Joseph Env Sci & Spec

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2.0 QUALITY SYSTEM COMPONENTS

The quality system of the SWQB consists of several interconnected components, including comprehensive planning activities, preparation of a detailed QMP, preparation of the SWQB QAPP, preparation of detailed sampling plans, individual technical assessments during the acquisition of environmental data and management assessments. Each individual in the SWQB is responsible for reviewing and following the appropriate QA/QC procedures during the planning, collection, preservation, and transportation phases of sample collection activities. In addition, supervisors are also responsible for overseeing the QA procedures of their staff. The SWQB QA Officer will assist all sections in their QA activities and will compile and maintain information on the quality of data generated by the SLD.

2.1 Documentation Each EPA-funded project that generates environmental data is required to have an approved QMP and an approved QAPP prior to the initiation of the sample-collection phase of the project. These documents will be reviewed and approved by the Program Manager, the Bureau Chief, the QA Officer and the appropriate Program Officer of EPA Region 6. In addition, the QMP will be reviewed by the EPA Region 6 QA Officer. The QMP describes the quality system of the NMED, SWQB, and SLD and sets forth a framework for conducting additional planning and sampling activities. The QA Officer will review and update the QMP at least annually. The QMP will be reviewed and approved by the Program Managers, the Bureau Chief, the QA Officer, the Division Director, the SLD Director of QA, the EPA Region 6 Project Officer and the EPA Region 6 Office of QA. The QAPP describes the specific sample-collection methods to be used by SWQB staff in collecting environmental data and describes the minimum quality of data required for decision-making purposes for the project, along with any special requirements or analytical methods needed to obtain that necessary quality. The QAPP will serve as a blueprint for the completion of the project and will be followed by all staff working on the project. All staff involved in a project should periodically review the QAPP and suggest revisions. The QAPP must be reviewed annually and updated if necessary. At a minimum, a letter must be sent to EPA Region 6 declaring that the QAPP is still complete and accurate. Management systems reviews will be conducted yearly in order to assess the effectiveness of the QMP and to update it. Standard operating procedures (SOPs) will be considered to be part of the QAPP and will be referenced by the QAPP. The review, approval and distribution procedures for SOPs will mirror those of the QAPP. DQO assessments will be conducted prior to the sampling phase of the project and will be documented in the project-specific sampling plan. For each project the necessary DQOs will be determined along with acceptable minimum levels of quantitation (MLs), preferred analytical methods and sampling site selections. The selection of each sampling site will be documented by the Project Leader and the watershed team for each project. This documentation will be sufficiently detailed to allow staff to assess the sampling sites in the future for continued relevance. The sampling plan will also include consideration of approved methods, SLD projected analytical workload, intended use of the data, levels of appropriate numeric water quality standards and any additional resource limitations. SWQB consultation with

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representatives of the SLD will determine the MLs and the possible analytical methods. Once appropriate DQOs have been determined, the QAPP and the sampling plan will be prepared and approved as above. Following the sampling phase of the study and the receipt of all analytical reports, a technical assessment of the methods used and their results will be conducted. Each Project Leader or Principal Investigator will give the SWQB QA Officer a list of the accession numbers of the QA replicate samples and the corresponding samples. When complete the SWQB QA Officer will transmit these numbers to the SLD Director of QA. The Director of QA will conduct an analysis of the QA data replicates submitted during the sampling season. Special note will be made of those data pairs that vary by greater than 20 percent. A formal report will be prepared and distributed by the SLD Director of QA along with recommended actions to correct perceived deficiencies. Recommended actions may include alterations in sampling or analytical procedures and alterations in MLs.

2.2 Tools for Quality Assessment The QAPP for each project generating environmental data should contain provisions for the collection of QA samples to be submitted to the SLD for these technical assessments. These samples are critical to assess all phases of sample collection and analysis. For example, ten percent blind QA replicates are collected during all intensive water quality surveys. These samples are submitted to SLD as separate samples from real or fictitious stations and the resultant data are compared with the original sample results. The results of these samples are used to document the sampling, preservation and handling techniques, and SLD analytical precision. QA replicates are collected in clean, unused containers of at least twice the size of the final sample. The container is, first, thoroughly rinsed with sample water and then filled with the sample. The container is capped and vigorously shaken to distribute all components as evenly as possible. The cap is then removed and the sample is poured into the final two sample containers, which were previously rinsed with sample water. The SLD analytical request forms for the QA replicates must not contain any indication that the samples are QA replicates. They should be labeled as coming from existing or fictitious stations that are credible. A QA replicate for a clear effluent discharge should not be labeled as coming from a river station that is always very muddy. QA replicates should be collected from various stations used for the survey. The QA replicates should not be collected from the same station during the entire survey. Analytical report forms for QA replicates should be marked with appropriate information as soon as received from the SLD in order to eliminate any doubt concerning the actual location (it is easier if the analytical request form is marked with a fictitious station on the stream). All SLD-assigned sample numbers for QA replicate/regular sample pairs are reported to the SLD Director of QA at the end of the calendar year and used to help minimize analytical problems. Individuals collecting the QA replicates should continually use the analytical results of the samples to refine sample collection, preservation and handling techniques as well as to determine SLD analytical precision. The SLD Director of QA oversees the QA procedures in place at the SLD and assures that all methods comply with the EPA-approved or -accepted methods of 40 Code of Federal Regulations (CFR) 136 (EPA 2000b). These include running appropriate EPA-required QA

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procedures during each analytical run and reviewing all documentation of QA proceedings. The SLD Director of QA is responsible for establishing the precision and accuracy of each analytical procedure used in SWQB environmental-data-gathering projects. Data for these QC procedures will be obtained by analyses of replicate, split and spiked samples, and blanks. These objectives will be accomplished by following the procedures for analytical QA specified in the Quality Assurance Plan for Chemistry Bureau Services (NMHD 2003a) and the Quality Assurance Plan for Biological Sciences Bureau (NMHD 2003b). The Director of QA at SLD also submits known samples marked as samples collected by the MAS in order to review the accuracy and precision of analyses. All instruments used to obtain data for the projects that generate environmental data must be maintained and calibrated according to manufacturer’s instructions. A record must be kept for each individual instrument, documenting all maintenance and calibration events and the individual responsible. Each section is encouraged to assign one staff member to be responsible for all section equipment. This person should be given the authority to assign duties involving the maintenance and calibration of equipment to other individuals. Data associated with instruments for which proper maintenance and calibration cannot be documented, should be used infrequently and with caution.

2.3 Roles and Responsibilities Activities and projects covered by this QMP include the following:

• Watershed Protection Section: The WPS collects environmental data to determine the efficacy of BMPs undertaken to reduce nonpoint source pollutants entering surface and ground water resources of the State. Among these projects are streambank stabilization, mineral impacts remediation, road construction BMPs and watershed protection. This section also assists in collecting water quality management data used for determining TMDLs. All activities of this section are federally funded.

• Point Source Regulation Section: This section conducts compliance sampling inspections at federally permitted NPDES facilities. The section also collects stream samples from above and below effluent discharges to determine possible effects on the receiving streams. The section collects samples of discharges from stormwater runoff and from above and below these discharges to determine possible effects on receiving streams. All activities of this section are partially federally funded.

• Monitoring and Assessment Section: This section conducts stream, lake, and playa water quality surveys to determine whether New Mexico’s water quality standards are met and designated uses are attained. This section conducts intensive water quality surveys for the purpose of gathering environmental data of sufficient quantity and quality to enable the determination of TMDLs. This section also conducts short-term investigations in response to emergencies and citizen complaints. The section also conducts studies to determine the level of various contaminants in edible fish tissue from waters throughout the State with primary emphasis on development of public health advisories for the consumption of fish. All activities of this section are partially federally funded. The data

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collected are used to determine impairment and 303(d) listing for purposes of TMDL development. All activities of this section are federally funded.

• Outreach and Special Services Team: This team does not collect environmental data.

• Financial Section: This section does not collect environmental data.

• Scientific Laboratory Division The SLD, a division of the NMHD, conducts laboratory

analysis for all water, sediment, and effluent quality samples collected by federally funded environmental data gathering efforts of the SWQB. All analytical procedures for federally funded environmental data gathering efforts of the SWQB follow the EPA-approved methods of 40 CFR 136 (EPA 2000b).

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3.0 PERSONNEL QUALIFICATIONS AND TRAINING

The State Personnel Office (SPO) determines position classifications used by New Mexico state governmental departments. For each position there is a formal description that includes minimum requirements for education, knowledge, experience, and examples of duties performed. These descriptions were determined by job delineations submitted by employees currently conducting similar activities. Specific employee qualifications are specified in the QAPP for each program. When a position is to be filled, the supervisor develops a list of qualifications for the position similar to the SPO specifications. SPO will advertise the position and submit to the supervisor the list of qualified individuals applying for the position along with copies of applications. The supervisor can also select a current State employee who meets all qualifications without going through SPO. Once an individual has been hired by the SWQB, some additional training is almost always required. Certain types of training, such as new employee orientation and driver’s training are required by the NMED for all new employees. Some types of training, such as cardiopulmonary resuscitation (CPR) and first aid, are recommended by policy for all new SWQB employees who will be working in the field. Many types of job-related training are encouraged by individual sections within the SWQB. Most new technical employees will serve a period of apprenticeship with experienced program personnel. The apprentice will receive “hands-on” training and will be verbally certified to the Program Manager by the experienced program personnel. The period of this apprenticeship for different tasks will vary greatly according to education, previous experience and the difficulty of the procedures. Due to limited funding for formal training, all employees are encouraged to attend low-cost or free training seminars and courses sponsored by the EPA and other federal agencies. Preference is given to attendance at courses or seminars held within New Mexico or in adjacent states and are also given for safety-related training. However, funding shortages should not prevent employees from requesting permission to attend appropriate educational opportunities—creative arrangements can be made. The NMED provides a Staff Development Coordinator (training officer), available to all employees, whose duties include maintaining lists and schedules of all available state training courses. The Staff Development Coordinator also will attempt to arrange courses on topics requested by staff at little or no cost to staff members or programs. The Staff Development Coordinator maintains training records for each employee and will notify individuals when requested training or required retraining is available. The Staff Development Coordinator will identify qualified trainers and will assess the effectiveness of all training activities. All staff attending training sessions are required to complete and submit to the Staff Development Coordinator and assessment of the course and the trainer. These assessments will be kept on file and will be used to determine future courses and trainers. Training materials and course content will be reviewed and updated by the SPO with input from all staff through the Staff Development Coordinator. It is understood that professional development beyond the minimum qualifications required for a position greatly benefits the NMED as well as the section and the individual. All employees are strongly encouraged to pursue further professional development. Educational leave, reimbursement of course costs, and work-schedule adjustments are just a few of the many ways

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that the SWQB can encourage further education. Some educational opportunities are available on-line or on video and can be accomplished as the employee’s schedule allows. The SWQB retains many instructional videos, as do the other NMED bureaus. A listing of all educational videos available in the NMED is maintained by the Staff Development Coordinator.

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4.0 PROCUREMENT OF ITEMS AND SERVICES QA requirements contained in 40 CFR 136 (EPA 2000b) and in the appropriate QAPP must be reviewed prior to specifying reagents, field supplies, or scientific instruments to be used in the generation of environmental data. It is strongly recommended that employees discuss scientific instrument and field supply requirements with EPA, SLD and other users of similar or identical products in order to be fully aware of the best currently available. The New Mexico Department of Finance and Administration issues contracts to vendors of frequently purchased items. If an item to be purchased is “on contact,” then it must be purchased from the contract vendor. Most reagents, field supplies and scientific instruments required by the SWQB for generation of environmental data will not be on contract. The product’s specifications must be closely examined to be certain that minimum requirements of the QAPP and 40 CFR 136 will be met. Minimum requirements must be clearly stated on the purchase order and a recommended vendor may be specified. The purchase order will be reviewed by the Program Manager, then reviewed and signed by the Bureau Chief before being processed. Any changes to the purchase order must receive the same scrutiny as the original document. Upon receipt of the reagents, field supplies or scientific instruments, the employee requesting the purchase must thoroughly inspect the products to determine that all specifications have been met and that nothing was damaged in shipment. Only after the satisfactory conclusion of this inspection will the invoice be processed for payment. If there are any problems with the order, the vendor should be contacted for exchange or replacement. If the vendor resists exchanging or replacing the item(s), then resolution will be sought through Administrative Services Division. Each section requesting a contractual agreement for generating environmental data must fully examine the potential contractors for the ability to carry out the proposed work. It must be kept in mind that the Program Manager and the Bureau Chief are ultimately responsible for the quality of the contractor’s output. A contractor selected to generate environmental data must agree in writing to adhere to all specifications in the QMP for Water Quality Management Programs or else to produce a new QMP acceptable to the SWQB. The Program Manager and the Bureau Chief are responsible for fully and specifically informing the contractor of all quality expectations, and for assuring that all items and services provided by contractors and suppliers meet those expectations. All contractor output must be thoroughly reviewed by the Program Manager and the Bureau Chief before the contractor will receive payment. All contractors and Section 319 grant recipients generating environmental data must have a quality system consistent with EPA specifications and must prepare a QAPP or a Proposal Quality Assurance Plan (PQAP) following guidance specified in EPA Requirements for Quality Assurance Project Plans (QA/R-5, EPA 2001b). Whenever a contractor or grant recipient will be collecting data covered by methods specified in the New Mexico QAPP for Water Quality Management Programs, the methods specified in that QAPP should be followed. The QAPP or PQAP document prepared would cover methods not included in the New Mexico QAPP. The acceptability of a PQAP in lieu of a full QAPP will be determined by EPA on a case-by-case basis. Data generated by a contractor or grant recipient under an approved QAPP or PQAP may be used by the SWQB.

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5.0 DOCUMENTS AND RECORDS

The SWQB produces a great number of documents and records and it is vital that these documents and records be verified for quality and stored in such a manner that the information contained is readily available to those who need it. There are several different kinds of documents and records produced or utilized by the SWQB, such as the following:

• Facility inspection reports, • Discharge monitoring reports, • Laboratory analytical report forms, • Field notes, • Photographs, • Equipment calibration and maintenance reports, • Survey reports, • TMDLs, • Correspondence, and • QA documents.

These documents and records have several different verification, handling and storage requirements.

5.1 Facility Inspection Reports and Discharge Monitoring Reports The facility inspection report is produced by the PSRS and covers, in detail, all observations made during a facility inspection. This report consists of an EPA Form 3560-3, a detailed listing of the findings, and any photographs taken during the inspection. The purpose of this report is to document facility compliance with NPDES permit requirements and EPA rules and regulations for the SWQB, the inspected facility and EPA Region 6. These documents, after being approved by the Program Manager, must be available for future reference. Copies of facility inspection reports with original copies or photocopies of photographs (if any) will be sent to the facility and EPA Region 6. These reports will be maintained in SWQB files for each facility with limited access, to ensure that the reports will not disappear or be altered. Effluent and stream sampling data and inspection reports are filed under the facility type and name. These files are maintained indefinitely—older files are transferred to microfiche. All water quality data generated are transferred to STORET.

5.2 Laboratory Analytical Data Laboratory analytical data that are received from the SLD (or other contract laboratory) have undergone extensive laboratory QA/QC procedures. The SWQB database manager will upload electronic data deliverables (EDDs) provided by SLD (in Microsoft Excel®) or other contract laboratories into the in-house database prior to data validation. Data received in hardcopy will be manually entered into a data-entry template (available in Microsoft Excel®) by the Project Leader or Principal Investigator and submitted to the database manager for upload to the SWQB in-house database. Data may be uploaded as available from the laboratory or may be entered as data sets are complete. Data are uploaded to the SWQB in-house database prior to data validation because the SWQB in-house database contains several data validation tools. All data collected during water quality surveys and facility inspections will, ultimately, be uploaded to

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STORET following validation of analytical results. A generalized SWQB QA protocol is summarized in Figure 5.1. The details of this data validation process will be provided in the “umbrella” document Quality Assurance Project Plan for Water Quality Management Programs (NMED/SWQB in progress). The Project Leader or Principal Investigator is responsible for rigorously checking all data for QA and signing the QA checklist, which provides a record of data validation (Figure 5.2). A file for each intensive and special survey is maintained for no less than six years. This file contains all SLD analytical forms, all non-privileged field notes concerning the investigation, instrument calibration results and all QA results for the survey. All analytical results received will be rigorously reviewed by the Project Leader or the Primary Investigator using the QA protocol (Figure 5.1), best professional judgment, knowledge of stream chemistry and effluent quality. The Project Leader or Principal Investigator will report any anomalous results to the appropriate section at SLD for a full review of the QA results of the relevant run, consisting of spikes, duplicates and concentration standards used to verify standard curves. The Project Leader or Principal Investigator will note and initial on the QA checklist, the results of this contact. The Project Leader or Principal Investigator may request that the sample be reanalyzed by the lab or may choose to collect a second sample.

5.3 Field Notes and Photographs Field notes are taken by all individuals conducting field studies and generating environmental data. These notes, along with photographs, are very useful to the Project Leader and Principal Investigator and allow that individual to review the trip in depth and to document findings. Field notes should be maintained for six years in the case of intensive and special water quality survey data and should be maintained indefinitely in the case of facility inspections. All photographs taken on film should be labeled to show the location and date and should be maintained permanently. All digital photographs should be printed out and this copy should also show the location and date and should be maintained permanently. Field notes constitute part of the official record, but may be privileged. Photographs are not privileged. Any privileged information should be kept in a separate file or in a separate section of the survey file. If information from the file is to be released, the privileged information should not be released.

5.4 Equipment Calibration and Maintenance Reports Complete procedures for operating, maintaining and calibrating instruments used in field environmental measurements are contained in the manufacturer’s instruction manual for each instrument. Personnel using field instruments are expected to read and be thoroughly familiar with all procedures detailed in these booklets. In particular, Project Leaders and Principal Investigators shall meticulously follow the calibration procedures given by the instrument manufacturer. A calibration and maintenance log shall be kept for each instrument. Dates of calibration, calibration methods used and any other pertinent data (e.g., erratic instrument behavior) shall be routinely entered in the logbook. All maintenance activities will also be entered in the logbook. Records shall be maintained for six years in the case of intensive and special water quality survey data and should be maintained indefinitely in the case of facility inspections.

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5.5 Survey Summaries Survey summaries of all intensive stream surveys and all lake/playa surveys conducted during the calendar year are to be prepared by the MAS. These summaries must be reviewed and approved by the Program Manager and the Bureau Chief prior to distribution. Survey summaries are prepared for EPA Region 6 and will also be distributed to interested State and federal agencies, municipalities involved in the study and any interested parties upon request. In addition, the surveys will be uploaded to the SWQB website organized by year, basin, and watershed at http://www.nmenv.state.nm.us/swqb/. Survey summaries may be used by the SWQB to develop plans for follow-up or verification sampling, for the development of TMDLs or for stream-use classification. Survey summary originals will be maintained indefinitely and additional copies will be produced as required. If a request is received for a large number of reports, then the Program Manager is authorized to charge a fee to cover copying and mailing.

5.6 TMDLs Intensive seasonal watershed studies are conducted for all waterbodies listed on the State’s 303(d) list and TMDLs are determined for those contaminants with confirmed violations of the water quality standards. The priority of these studies is, in part, determined by the consent decree (Forest Guardians and Southwest Environmental Center v. Carol Browner, EPA (U.S. District Court for the District of New Mexico 1997). The TMDL documents are released in draft form for, at a minimum, 30-day public review period. The updated TMDL document is then presented to the WQCC for adoption. Once adopted, the TMDL document becomes a part of the New Mexico water quality management plan. TMDL documents will be maintained indefinitely until removed by action of the WQCC. The documents will be listed in the body of the management plan and copies will be placed on the NMED web site (http://www.nmenv.state.nm.us/).

5.7 Correspondence Written and electronic correspondence provides the documentation for most contacts and actions between the SWQB and state, federal, local, or private entities. The correspondence should, therefore, be kept indefinitely to document past actions. Correspondence involving violations must be reviewed by the Program Manager and the Bureau Chief and must be sent certified mail, return receipt requested. The certifying number must be typed on the correspondence and the receipt must be stapled to the letter when received. Most correspondence is not privileged. Notes or comments should not be written on the margins of correspondence to be placed in files, since this type of document is not privileged and may need to be released under the Public Records Act. Electronic mail (email) documents are considered to be official and, as such, are subject to public review under the Public Information Act. Printed copies of all significant email should be made and placed in the appropriate files as part of the official record.

5.8 Quality Assurance Documents QA documents must be maintained for the life of the project plus six years. These documents include the QMP and the QAPPs, analytical reports from QA replicates collected by staff in conjunction with intensive surveys, and reports from the SLD Director of QA. The SLD Director of QA determines bias by analyzing the results of conventional methods and blank spike data and by analyzing the accuracy of the method through the use of reference standards. Commercially prepared and in-house prepared check samples are also analyzed on selected

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parameters. SLD participates in a quarterly external check-sample program for chemical and radiochemical analyses. SLD also participates in the required National Exposure Research Laboratory (NERL)/Las Vegas performance evaluation and check-sample program, the NERL/Cincinnati water pollution check-sample program and a commercial proficiency monitoring program funded by EPA. Results from all of these QA procedures must be maintained for the life of the project plus six years.

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ConductSampling Run,Retain Copy ofSubmittal Sheet

Transfer RIDs and field data

from field forms

to database

Step 1b: Evaluate

RIDs/Field Datafor

Consistency

Correct Errors and/or

DeleteUnused RIDs

SLD DataUpload by DatabaseManager

Check for Incorrect Field Measurement

Values & Unused RIDs using

Database Tools

Step 2: Validate Analytical

Data

Checkfor Missing Chemical Data using

Database Tools

Potentialoutlier(s)?

Identicalrecord(s)?

Provide data-base mgr with

list ofrecords to delete

Evaluate RPDsfor Field

Duplicate-Sample

Pairs usingDatabase Tools

No

RPDs OutsideControlLimits(CLs)?

Yes

Provide data-base mgr with list of duplicate

pairs withassociated

validation codes

Evaluate Dissolved

Metals Results Greater Than (>)

Total Results usingDatabase Tools

Yes

Provide data-base mgr with list of outliers

and validation codes

Unused RIDs

in Data-base?

Errors inField

Measure-ments?

Provide database mgr with list ofDis records >Total and theassociated

validation codes

Review Field Notesfor Results

That Should BeRejected or

Qualified

No

Provide database mgr with list of

records and validation codes

Step 1a: Evaluate

Field Stationsfor

Consistency

Sort and QAGeographic

Data

CorrectTypographical

Errors

Duplicate or Incorrect

stations?

Stations in wrong

segment?

Request thatDatabaseManager

Contact SLD,Procure, & Up-

load Data

MissingResults?

Conduct review for iden-tical records &outliers using

Database Tools

(Upload)

No

Yes

Diss.Results >

Total at RPD AboveCL?

Step 3: Prepare QA

Checklist andSubmit QA

Package to DBManager

YesSampleintegrity

compromisedin the fieldb?

Yes

Review AnalysisDates using

DatabaseTools to EnsureHolding Times

were met

HoldingTime

Exceeded?

Yes

Provide database mgr with

appropriatelist of

records and validation codes

No

No

Yes

Yes

Export data toExcel® using

Database Tools- Manually check for Missing Info.

or Anomalies

MissingInformation

orAnomaliesa?

CompleteData VerificationForm and Sendto SLD through

DB Mgr. who will correct problems

No

(Correct DB)

Yes

No No

Yes

No

5-5

Figure 5.1 Quality Assurance Protocol, New Mexico Environment Department, Surface Water Quality Bureau

Notes: aMissing information/anomalies may include missing detection limits, incorrect “less than” field, incorrect results, etc. bField notes may indicate that a sample was preserved improperly, or otherwise contaminated/altered. Data should be rejected if compromised. SLD = Scientific Laboratory Division RID = Request identification QA = Quality Assurance DB = Database CL = Control Limit > = Greater than RPD = Relative Percent Difference

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Figure 5.2 Quality Assurance Checklist, New Mexico Environment Department, Surface Water Quality Bureau STUDY NAME: _________________________________________________________

DATE(S) OF SAMPLING EVENT(S): ________________________________________________________

STUDY LEAD: _____________________________________________________________________________

CHECKLIST OF ITEMS REVIEWED:

1. Presence of Identical Records or Possible Outliers

Action Required No Action Required

2. Field Duplicates within Control Limits

Action Required No Action Required

3. Total Metals versus Dissolved Metals

Action Required No Action Required

QUALITY ASSURANCE SUMMARY:

Based on the quality assurance review, data for the above samples are: Acceptable for use Acceptable as qualified Unacceptable for use

Is action required on any QA items? Yes No Explain: Location IDs RIDs ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ ________________ Initial QA Reviewer (Study Lead): __________________________ Date: _____________ Database Editor: ________________________________________ Date:______________ STORET QA Reviewer: ___________________________________Date:______________

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6.0 COMPUTER HARDWARE AND SOFTWARE

Automated data processing is becoming ever more important in the daily activities of the SWQB. Records, correspondence, analytical data and reports are being produced, updated and stored on computer systems. Personal computers (PCs) are the standard in the SWQB, although X-terminals connected to the NMED network are used for some word processing, vouchering, communicating and data sharing. The SWQB purchases PCs with the fastest processors that can be economically obtained for general use. Special uses and intensive graphics work require the fastest processors available, regardless of expense. Older computers will be upgraded with new motherboards or replaced as funding allows. All new computers acquired will have networking capability and will be connected to the NMED network for email, accessing the internet, accessing STORET and other data bases, and for sending and receiving information. All new computers to be used for STORET access will be Windows 2000® or Windows ME® compatible and have a Compact Disc - Read Only Memory (CD-ROM) drive. Windows-based programs are used whenever possible, although it is recognized that certain older Disc Operating System (DOS)-based programs will continue to be used where special applications have been developed. The standard for printers is the Hewlett Packard series laser printers. A few dot-matrix printers will be maintained for printing multi-part forms. New Mexico State government has standardized on Microsoft Word® and Microsoft Excel® for word processing and for spreadsheets. Database management software, statistical packages, GIS, etc. will be selected for the specific application. Purchases of data processing hardware and software must be approved by the SWQB Data Processing Specialist, the Program Manager, the Bureau Chief and Information Technology Services (ITS). The Information Systems Analyst will continually review software and hardware and recommend upgrades and new purchases to users. ITS will maintain a roster of minimum specifications for computers purchased by the Department and will review all purchase orders. The agencies entering data on the STORET data system are responsible for documenting quality of the environmental data and for setting acceptable standards. Data downloaded from STORET will depend on the source(s) of the data. Data stored by this SWQB have met the rigorous standards applicable at the time of data collection and storage. Data stored by other agencies can be used, but the sources of the data must be stated. Data collected from computer-controlled devices (such as the Isco Automatic Samplers) will be considered valid as long as all procedures specified by the manufacturer are followed and documented. All computers must be password-protected at “powerup” and have password-protected screen savers or keyboard protection. Screen savers or keyboard protection programs with a “hot key” (instant on) function are preferable to those that come on only after a specified time interval. The Information Systems Analyst will frequently check all areas of the SWQB for computers left unattended without password protection. The Information Systems Analyst will maintain a list of all passwords in use in the SWQB. All floppy disks received from outside of the SWQB, whether from the NMED, other State or federal agencies or from the private sector, must be checked for the presence of viruses before being used. This is of the utmost importance since infected disks have been received by the SWQB from each of these sources.

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All software licensing agreements must be strictly adhered to. Particular attention must be given to application “suites”—those combinations of several different types of software from a single company purchased as a package. The licensing agreements for these suites generally require that all the applications be loaded on a single computer and they not be divided among several different systems. Some software licenses allow the use of the same programs on a desktop computer and a laptop computer used by the same individual, as long as both computers are not being used at once. Careful review of the software licenses should be made. The Computer Systems Analyst is responsible for reviewing hardware and software licenses. Applications on a desktop computer can sometimes be shared with a laptop computer, as long as the computers are never used simultaneously. The SWQB goal is for all computers to have non-interruptible power sources in order to reduce the loss of data files. Electronic data must be backed up frequently. The goal is for all users to have access to a tape back-up unit or Compact Disc - Recordable (CD-R) in order to back up the entire hard drive weekly. Many computers will need to have the data only backed up to discs. Backups of data files should be made at least weekly—backups of frequently updated data files should be made at least daily. Floppy disk drives must be cleaned at least monthly. No food or drinks may be used around electronic data-processing equipment. The SWQB developed an in-house water quality database in Microsoft Access®, which combined elements of the EPA Assessment Database (ADB) Version 1 and Biogeographic Information Observation System (BIOS) in order to house chemical, biological, and physical water quality data collected by the SWQB during intensive watershed surveys and Section 319 project monitoring. Development of this database was initiated in 1999 when EPA shut down the Legacy STORET system in order to revamp the entire STORET database. The in-house water quality database serves as a local repository for provisional and final data, and also contains a variety of automated tools for planning surveys, performing QA tasks, and assessing data to determine use impairment status. Now that STORET is back on-line, chemical water quality data is uploaded to the national STORET database from the SWQB in-house water quality database. All summary assessment information is currently housed separately in ADB Version 1. SWQB is in the process of migrating to ADB Version 2 in order to take advantage of the automated integrated categorization features for development of the Integrated CWA §303(d)/305(b) List of Assessed Surface Waters. This migration will be completed by March 2004. SWQB has also developed an in-house NPDES tracking database. During 2004, NPDES information will be migrated into the NMED Integrated Database for Environmental Assurance (IDEA) database so that all NMED staff will have access to NPDES information. SWQB is currently using the EPA-developed Ecological Data Application System (EDAS) Version 3.0 database to house benthic macroinvertebrate and fisheries data for bioassessment development purposes.

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7.0 PLANNING

The citizens of New Mexico represent the ultimate customers of the environmental data gathered by the SWQB. In general however, raw field and laboratory data are analyzed and summarized before being made accessible to the public. Therefore, the technical and management staff of the SWQB and the NMED who prepare, edit, and approve these summaries and reports are the primary customers of the generated environmental data. The EPA is also a customer of much of the data, and its QA requirements must be taken into consideration. Due to limitations in staff and funds, some environmental data collected will be used for several diverse purposes. It is important that data that may ultimately be used for multiple purposes meet as many of the identified requirements for these purposes as is possible.

7.1 Data Requirements Data requirements fall into several general categories: sample collection, preservation and handling, analytical methods, and QA procedures. Data requirements are determined by the individual programs and must be documented in the applicable QAPP before any data-gathering activities take place. Environmental data-gathering activities funded at least in part by EPA grants must meet EPA-specified requirements. These requirements are normally found in 40 CFR 136 “Guidelines Establishing Test Procedures for the Analysis of Pollutants Under the Clean Water Act” (EPA 2000b). Some types of data-collection activities (such as the high-resolution mercury monitoring program) might require very low detection limits and experimental techniques not found in 40 CFR 136.

7.1.1 Performance Criteria Each program must determine the quality of data that is acceptable and the requirements for documenting that level of quality. Each program must also determine acceptable MLs along with the projected analytical costs and sample turnaround times. Lower MLs generally increase both the cost and the turnaround times. The acceptable MLs and the QA documentation requirements for each program must be documented in the QAPP. The requirements specified in the QAPP should be continually reviewed and evaluated, but must be reviewed and evaluated at least annually. Any changes in requirements or procedures should be determined prior to the initiation of the next data-collection cycle, if possible. Methods by which the generation, acquisition and use of environmental data shall be planned will be documented in the QAPP. The success of each program or activity will be determined based on the percentage of projected work plan requirements that have been met. It is possible that not all projected requirements are met, and yet, the program is considered a success because samples were obtained during a runoff event or during some other situation that yields valuable information rarely obtained. It is also possible that more than 100 percent of the requirements will be met. Success will be determined by the Project Leader or Principal Investigator.

7.1.2 Study Design A separate sampling plan must be prepared for each individual survey conducted by the SWQB. This sampling plan will document the decisions made by the watershed team concerning goals of the study, choice of sampling stations and DQOs. The sampling plan must have information for each sampling station selected regarding the reason for its selection and the reach or condition it

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is to represent. The information in the sampling plan will allow a more complete record of the survey and will serve to document the reasons behind sampling station selection for the watershed team that will study the watershed in the future.

7.2 Project Coordination The Program Manager is responsible for ensuring that lines of communication among all interested data users are kept open in the planning and implementation phases of environmental data collection. Environmental data collection frequently involves cooperation and coordination with several different entities, such as other sections, bureaus, agencies, field offices, tribes and citizen’s groups. The SLD shall be kept informed of the analytical needs of the programs by the SLD Coordinator and by direct communication from Program Managers, Project Leaders and Principal Investigators. The SLD must be informed of sample collection and delivery times so that Specimen Receiving staff are prepared and so that analytical sections are aware of upcoming workloads. This notification, although always important, is of vital importance when the constituent of interest has a short holding time. The SLD has limited capacity, staff and equipment to conduct analyses of microbiological, organic, and cyanide samples, and these analyses must be scheduled in advance. SLD must also be contacted when a sample priority other than priority 3 is required. The Bureau Chief must approve a sample priority change and the SWQB QA Officer must contact the SLD in person. All samples received at SLD without proper phone authorization by the QA Officer will be changed to priority 3 without contacting the submitter. Cellular phones are available to field crews and allow greater ease of communication with SLD during the field portion of an environmental data-gathering effort. Proper communications are vital.

7.3 Documentation Documentation must be produced for many of the environmental data-collection activities conducted by the SWQB. This documentation allows the Project Leader and field crew to review a sample-collection trip many months later and allows another individual insight into the collection activities in the case where there are personnel changes between sample collection and data analysis. Examples are documentation of the proper maintenance and calibration of instruments, date and time of collection, conditions during sampling, general observations, and observed perturbations in conditions. It is advised that Project Leaders and field crew maintain a field log for all of their sampling activities. The documentation necessary for a particular program will be specified in the QAPP.

7.4 Health and Safety Health and safety of employees is of utmost concern to the NMED and the SWQB. Health and safety concerns should be anticipated and identified prior to the initiation of sample collection activities. Staff must be familiar with the use of health and safety gear and this gear must be available during the sampling trip. This gear includes:

• emergency eye-wash station • eye protection

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• acid-resistant apron • acid-resistant gloves • first aid kit • cellular phone or emergency radio

Although general health and safety concerns can be anticipated before the data-gathering activities begin, some unanticipated concerns might occur during the activities themselves. The Project Leader and field personnel must determine whether situations are too hazardous to collect samples from a given location at a particular time. Severe weather or stream flooding are situations during which extreme caution must be exercised. Because of the continual prospect for unforeseen problems, field teams generally consist of at least two individuals. In the event of a situation in which a personal threat is made against a member of the field crew by an individual hostile to the NMED, the field crew should immediately leave the area and contact the Bureau Chief and the State Police. Field personnel should not take unnecessary chances.

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8.0 IMPLEMENTATION OF WORK PROCESSES

This section describes procedures to be implemented to ensure an acceptable level of data quality. The QAPP and sampling plan, the blueprints for implementing almost any SWQB project that involves the generation of environmental data, are discussed in addition to sample-collection activities, sample preservation, and transportation of samples.

8.1 Planning and Technical Documents The QAPP, along with the sampling plan, is the blueprint for implementing almost any SWQB project that involves the generation of environmental data. Once in effect, a QAPP has been reviewed and approved by management and the technical staff, which have the responsibility and capability for ensuring that all procedures documented in the QAPP are carried out. The level of management oversight required by a program will vary depending on the experience and training of the personnel, difficulty of procedures, the importance of the program and whether the project has been conducted for many years or is new. The QAPP contains documentation of all procedures required for that program. The “umbrella” QAPP will be in effect for one year, generally to correspond with the sampling seasons, and must be reviewed and updated annually. All changes in equipment, sampling procedures, etc. must be updated. If there are no substantive changes to a QAPP, at a minimum the signature page must be updated and all new signatures obtained. A signature on the document certifies that the individual agrees to be familiar with and to follow all appropriate procedures. The distribution list for the QAPP is contained at the beginning of the document and indicates those individuals who will receive the QAPP and all updates. Since pages can tear out of loose-leaf copies, and the task of assuring that all copies are completely updated is difficult, it is recommended that the QAPP be bound and that complete new copies be distributed each year, unless the only change is the signature page. The SWQB QAPP will be prepared according to the EPA Requirements for Quality Assurance Project Plans (QA/R-5, EPA 2001b) and EPA Guidance for Quality Assurance Project Plans (QA/G-5, EPA 2002). The SWQB QAPP will be reviewed and approved by the Program Managers of those sections generating environmental data, the Bureau Chief, the SLD Director of QA and the SWQB QA Officer prior to being submitted to EPA Region 6 for approval. The Bureau QAPP must emphasize that procedures documented will be followed during the project. If any situations require deviation from the documented procedures (such as flooding or inclement weather), this deviation must be thoroughly documented in the field notes and in the resultant report.

8.2 Sample Collection Certain activities are common to most environmental data-gathering projects. These include certain sample-collection activities, sample preservation and transportation of samples to the SLD. Unless otherwise specified in the QAPP, the following procedures apply: Water temperature and conductivity, turbidity, dissolved oxygen, percent oxygen saturation and hydrogen ion concentration are measured on-site using a multi-parametric sonde and datalogger (Yellow Springs Instrument Company). If a potential source is present, total chlorine residual is

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measured using a specific ion-probe (Orion) or the EPA-approved N,N-diethyl-p-phenylenediamine (DPD) method (EPA 1997). Water samples for determination of ammonia, nitrite plus nitrate, Kjeldahl nitrogen, phosphorus, non-filterable and filterable residues, major cations and anions and total metals are collected in clean one-liter polyethylene containers. Water samples for determinations of dissolved metals are collected in clean one-gallon polyethylene containers. At the site, each container is thoroughly rinsed with the sample water before the grab sample is collected. Grab samples are collected in such a manner as to minimize the contact of the sample water with the collector’s hands. The samples are preserved as indicated below, cooled on ice to 4 degrees Celcius (oC), and transported in ice chests to the SLD. Samples for nutrient analyses are preserved at the sampling site with two milliliters (mL) of concentrated sulfuric acid; samples for total metals analyses are preserved with five mL of concentrated nitric acid. Samples for dissolved metals analyses are filtered using disposable 0.45-micron Geotech dispos-a-filters® under a pressure differential with new or clean Tygon® tubing. Clean one-liter polyethylene containers are rinsed with filtered sample water and then filled with filtered sample water and preserved with five mL of nitric acid. When samples must be collected from a bridge or dam, the sample is collected in a clean plastic or stainless-steel bucket using a nylon rope. The first bucketful of water is used to rinse the bucket and the sampler’s hands. Samples are collected from the second bucketful of water. A third bucketful of water is used to measure temperature and specific conductance. The probe of the conductivity meter has a lead weight attached, which cannot touch the sample water prior to collecting samples for heavy metals. Likewise care must be taken in allowing any metallic objects to touch the sample water or the sampler’s hands prior to sampling. Water samples for determinations of densities of fecal coliform bacteria are collected in sterile wide-mouth 100-mL polypropylene bottles containing sodium thiosulfate to neutralize any chlorine residual present. The person collecting the sample must be very careful to not contaminate the sample during collection. After collection, the sample is cooled on ice to 4oC and transported in ice chests to the SLD within six hours of the sampling time. Water samples for determination of biochemical oxygen demand (BOD) (5-day) are collected in clean one-liter polyethylene containers, cooled on ice to 4oC and transported in ice chests to the SLD within 48 hours. SLD must be notified prior to collected either of these types of samples. Water samples for determinations of pesticides and other organic chemicals are collected in glass containers provided by the SLD Organics Section. The SLD must be contacted prior to sampling in order to notify them of samples that will be coming in and also to obtain the proper sampling containers, labels and preservatives. The containers, preservatives and information to be contained on the request forms change frequently, as do recommendations for clean sample-collection techniques. Sample containers for organics samples must be kept in a cool ice chest after being obtained from the SLD and before use. Organics bottles must never be left in a hot vehicle or a vehicle trunk—the heat will volatilize any plastics in the vehicle (including vehicle parts) and will contaminate the bottles. If organics samples must be collected from a bridge or dam, the sample is collected in a clean stainless-steel bucket using a new nylon rope. Older nylon ropes will fray and drop small particles of nylon into the sample. All care must be taken to

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ensure that the sample collector’s hands are clean. The sampler’s hands must be rinsed vigorously in the water to be sampled; if sampling from a bucket, the first bucketful of water is used to rinse the hands and the second bucketful is used for sampling. An attempt is made to collect the sample without having the water flow over the sampler’s hands. The individual collecting the organics samples should not have handled cubitainers or other plastics just prior. Organics samples should not be collected subsequent to samples collected in polyethylene containers by the same individual. The individual collecting the organics sample should not have pumped gasoline or handled other organic solvents on the day of the collection. After collection and proper preservation, organics samples are cooled on ice to 4oC and transported in ice chests to the SLD.

8.3 Quality Assurance QA replicates for all chemical and microbiological parameters are collected at the sampling site. These replicates should be collected in clean unused containers of at least twice the size of the final sample. The container should be thoroughly rinsed with sample water and then filled. The sampling container should be capped and vigorously shaken to distribute as evenly as possible all components. The cap should be removed and the sample poured into the final two sample containers, which were previously rinsed with sample water (except for fecal coliform bacteria sample containers, which are never rinsed before sampling). Duplicate samples for dissolved heavy metals are taken from the same one-gallon sample as the original, using the same filter, if useable. The frequency required for duplicate sampling is one in ten samples. Duplicate samples are submitted to the laboratory as blind samples, i.e., the location and other information given on the label does not reveal that the sample is a duplicate. The analytical results of duplicate sampling are entered into the STORET database and identified as QA replicates. All samples for analysis at SLD are cooled to 4°C and stored and transported in ice chests. Ice levels must be frequently checked to ensure that sample temperatures are being attained. Care must be taken with organics samples to ensure that the samples are at 4°C upon arrival at the SLD. The bottles are frequently delivered from SLD with fitted bubble-packs around each bottle. While these bubble-packs help prevent the bottles from rubbing during transport and possibly from breaking, they also prevent the bottles from cooling very efficiently during icing of the samples. When sampling, remove all bubble-packs from around the bottles and after sampling, completely cover bottles with ice. Organics samples can deteriorate rapidly at temperatures above 4oC. The Specimen Receiving Section at SLD can determine sample temperature using a non-invasive infrared detector. Samples above 4°C will be rejected by SLD. All organics sample request forms should contain, in the remarks section, a request for a report of the sample temperature upon arrival at Specimen Receiving.

8.4 Sample Submittal All samples submitted to SLD must have the proper SLD analytical request form. Photocopies of the completed forms should be retained for SWQB files. These forms are completed in the field prior to sample delivery to SLD. All samples must have an SLD sample identification sticker attached. These stickers can sometimes come off when the containers are immersed in ice. To prevent this, the sticker can be covered with clear package-sealing tape. This sticker must be identical to the one placed on the analytical request form. All analytical request forms must contain the following information:

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1. User code number (assigned by SLD). 2. SLD sample identification sticker. 3. Priority code (usually “3.” If priority of the sample is “1” or “2,” this must be

approved in advance by the Bureau Chief and the SLD must be contacted by phone by the SWQB SLD Coordinator).

4. City, county and state. 5. Complete sample location 13-digit STORET station ID. 6. Name of the individual collecting the sample. 7. Complete sample collection date and time. 8. Submitter code (assigned by SLD) and/or Program Manager to receive report forms.

In addition, for samples for parameters other than fecal coliform bacteria:

1. Type of sample (grab, composite, split or chain-of-custody). 2. Sample source (stream, lake, waste water treatment plant [WWTP], etc.). 3. Sample type and volume (water, wastewater—1-liter or 4-liters). 4. Type of preservation and whether or not sample has been filtered. 5. Type of analysis requested. 6. Additional field remarks (this space must contain a request for date and time of

analysis and name of person conducting the analysis). 7. For all heavy metals samples, the corrected or uncorrected conductivity of the water

at the sampling station must be included on the form. Waters with very high specific conductances may damage laboratory analytical instruments!

8. For all organics samples, include in the remarks section, a request to measure and

report the temperature of the sample upon arrival at SLD.

Analytical request forms for fecal coliform bacteria must contain:

1. Type of system (stream, effluent).

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2. Whether or not the water has been disinfected and if so, the approximate disinfectant residual.

3. Type of test—membrane filter (MF) or most probable number (MPN). If in doubt,

indicate that either method may be used if appropriate—the MF method may not be appropriate in waters with high total suspended solids (TSS) or turbidities. The MPN method must be used for effluent samples collected for enforcement purposes.

4. Reason for sampling (monitoring sample). 5. Name and address of Project Manager (survey lead) to whom the report will be sent.

Samples may be rejected by the SLD if the above information is not contained on the analytical request form. Field measurements are entered on a field sheet or in a bound field notebook. Samples collected from effluent discharges may potentially be used for enforcement, and therefore, must be transmitted to the SLD under strict chain-of-custody procedures. These procedures are detailed in Chapter Five of the NPDES Compliance Inspection Manual (EPA 1994), in the Quality Assurance Plan for Chemistry Bureau Services (NMHD 2003a) and the Quality Assurance Plan for Biological Science Bureau (NMHD 2003b). The chain-of-custody form (or equivalent) must be completed by the Project Leader or Principal Investigator and in turn by every individual receiving custody of the samples before delivery to the SLD. The chain-of-custody tag must be affixed to the sample container with evidence tape in such a manner that it would be impossible to open the container without breaking the tape. Responsibility for samples is transferred to the SLD the moment they are accepted by the Specimen Receiving Section. Samples are assigned an identification number and logged into a ledger that provides for the tracking of the sample until all analyses are performed and reported. The Specimen Receiving Section is responsible for distributing the samples to the appropriate analytical laboratory section. The supervisor of the analytical laboratory section takes custody of the sample and is responsible for further distribution or storage. The sample-handling procedures of the SLD are in accordance with Section 15, Sample Control and Chain of Custody, in the Handbook for Sampling and Sample Preservation of Water and Wastewater (EPA 1982).

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9.0 QUALITY SYSTEM ASSESSMENT AND RESPONSE

For any quality system to work properly and effectively there must be feedback on how well the system is working and there must be a mechanism in place for implementing improvements in reaction to the feedback. Environmental data generated by the SWQB is used by the SWQB, EPA and the public, as well as various consultants, municipalities, and institutions of learning. In order for the SWQB to fulfill its mission and obligations, it is necessary to continually assess management, procedural, and technical requirements. The four general types of assessments are described below:

1. Management self-assessment: The qualitative assessment of a particular program operation by those responsible for performing and overseeing the work to determine whether the policies, practices, and procedures used are adequate for ensuring that the type and quality of results needed are being obtained.

2. Management independent assessment: The qualitative assessment of a particular

program operation by someone other than those responsible for performing and overseeing the work to determine whether the policies, practices, and procedures used are adequate for ensuring that the type and quality of results needed are being obtained.

3. Technical self-assessment: The technical assessment of a particular program operation

by those responsible for performing and overseeing the work to determine whether the techniques and procedures used are adequate for ensuring that documented specifications and objectives are being met.

4. Technical independent assessment: The technical assessment of a particular program

operation by someone other than those responsible for performing and overseeing the work to determine whether the techniques and procedures used are adequate for ensuring that documented specifications and objectives are being met.

Assessment is a responsibility of all SWQB personnel, but falls most heavily on the QA Officer, the Bureau Chief, Program Managers, Principal Investigators and Project Leaders. The QA Officer, along with the Bureau Chief and the Program Managers, will assess and document at least annually the adequacy of the QMP methods, the effectiveness of the implementation, and the adequacy of resources and personnel to achieve the quality objectives in all activities to which the QMP applies. These management systems reviews will focus on how the integrated quality system is working and will identify and correct management barriers that prevent full attainment of objectives. Any changes to the quality system will be documented in the QMP.

9.1 Roles and Responsibilities Field sampling and measurement techniques are continually undergoing review and modification. All field personnel are encouraged to question current methods and techniques and to propose and evaluate new methods and techniques. The findings of these evaluations should be shared and discussed by all personnel. Decisions will be made by consensus whether to continue with existing methods and techniques, switch to new methods and techniques, or to use combinations of both. Any changes to procedures will be reflected by changes in the QAPP.

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It is important that technical staff from one section or program occasionally interact with technical staff from other sections and programs in order to share new ideas and techniques and to question existing procedures. The MAS staff will collect QA samples to be equal to at least ten percent of the Section’s total sampling load. The SLD accession numbers of the QA replicates will be provided to the SLD Director of QA at the end of the sampling season. The SLD Director of QA will evaluate the results of these samples and will prepare an annual summary report. The SWQB QA Officer will share this report with the Bureau Chief, the Program Managers and EPA Region 6. It must be noted that procedures for splitting samples in the field can be a source of variability in analytical results along with analytical techniques. Project Leaders, Principal Investigators, and field staff must continually assess and refine QA sample-collection procedures. The QA Officer, along with the Bureau Chief and the Program Managers, are responsible for selecting the assessors, defining criteria, and identifying goals prior to the initiation of an assessment. Criteria for these selections should be detailed in the QAPP and the sampling plan, including the assessor’s qualifications and the assessment schedule. Personnel conducting assessments for programs other than those in which they work will be knowledgeable concerning program requirements and will be technically proficient in program areas. Assessors should have no real or perceived conflicts of interest. Assessors will be given sufficient authority, access to program and managers, and access to documents and records to fully perform the assessment. These assessment activities will have the full support of the SWQB and the NMED, since the benefits derived are vital to the SWQB’s and NMED’s missions and goals. The first step in any assessment is to confirm that all procedures and techniques documented in the appropriate QAPP are being followed. If all procedures and techniques are being followed, then it must be determined whether or not these procedures and techniques are adequate to result in the consistent generation of environmental data under a variety of conditions. The assessor is responsible for follow-up reviews to confirm implementation and effectiveness of solutions. When an existing or potential quality problem has been detected, the Bureau Chief and Program Manager will be notified in writing. The Program Manager is responsible for overseeing any further work conducted prior to the implementation of solutions. If the quality problem is of sufficient magnitude to preclude the collection of quality data, data-collection efforts must cease until an acceptable solution has been determined and put into effect. If a problem is detected that could affect the health or safety of personnel, the assessor has the authority and the responsibility to immediately halt work until a solution can be found. The assessment results will be documented in writing, including the problem detected and the solution recommended and/or implemented. Any generated data that are of limited or questionable quality will be flagged. The specific methods of assessment and the resultant response actions will be documented in the QAPP. Another important activity of the assessor is to identify and cite noteworthy practices and successes and to share these with other programs and sections. This practice recognizes important individual contributions and also shares recipes for success. The Program Manager and QA Officer are responsible for reviewing the assessor’s report.

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9.2 Corrective Actions All environmental data used by the SWQB that have not been collected under an approved QAPP either by the SWQB or by outside entities, must be qualified for the intended use. Data collected by municipalities, consultants, students and the public should only be used when absolutely necessary and then a statement must be included concerning the origin of the data. Reduced emphasis must be given to data not collected under an approved QAPP, and every effort should be made to collect concurring samples, if possible.

9.3 Technical Review All project reports shall receive vigorous review by technical peers, the Program Manager and the Bureau Chief prior to publication. No reports will be sent out without Program Manager and the Bureau Chief approval. In special rare instances draft reports may be released to concerned individuals with a demonstrated need for the report. In these cases Program Manager and Bureau Chief approval must be obtained and every page of the report must clearly state “DRAFT - not an official NMED report.”

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10.0 QUALITY IMPROVEMENT

For any quality system to reach its optimal level of efficiently and effectively detecting and preventing quality problems and for ensuring continuing quality improvement, it must be fully supported by the management system at all levels. Management must stress quality in all activities, and staff must recognize and support this emphasis on quality. The SWQB and the SLD are committed to high quality data-generation activities and to the continual assessment and improvement of their respective quality systems. All staff members are encouraged to identify process improvement opportunities, identify existing or potential problems and offer solutions to these problems. In this time of decreasing resources it is imperative that better environmental data be generated with reduced effort whenever possible.

10.1 Quality System Components The quality system of the SWQB consists of several interconnected components, including comprehensive planning activities, preparation of a detailed QMP, preparation of detailed QAPPs, individual technical assessments during the acquisition of environmental data, and management assessments. Each individual in the SWQB is responsible for reviewing and following the appropriate QA/QC procedures during the planning, collection, preservation, and transportation phases of sample-collection activities. In addition, supervisors are also responsible for overseeing the QA procedures of their staff. The SWQB QA Officer will assist all sections in their QA activities and will compile and maintain information on the quality of data generated by the SLD. The QA Officer is also responsible for assessing management system quality problems raised by SWQB staff and should identify the root causes of the problems to determine if the problem is unique or has implications that are more generic. The QA Officer has the responsibility for recommending changes to the management system and to procedures in order to prevent recurrence. The QA Officer will review and update the QMP at least yearly. The QMP will be reviewed and approved by the Program Managers, the Bureau Chief, the QA Officer, the Division Director, the SLD Director of QA, the EPA Region 6 Project Officer and the EPA Region 6 Office of QA. Each program must determine the quality of data that is acceptable and the requirements for documenting that level of quality. The acceptable MLs and the QA documentation requirements for each program must be documented in the QAPP. The QAPP for each program contains documentation of all procedures required for that program and serves in place of written SOPs. The QAPP and the sampling plan will serve as a blueprint for the completion of the project and will be followed by all staff working on the project. Great care will be given to the planning of each project to help prevent or minimize problems that might affect the quality of environmental data. The planning of each project will be documented in detail in the sampling plan. Each QAPP will be in effect for one year, generally to correspond with the sampling seasons. The sampling plan will be in effect for the duration of the project, usually less than one year. The requirements specified in the QAPP should be continually reviewed and evaluated by all program staff, but must be reviewed and evaluated at least annually. Any changes in requirements or procedures should be determined prior to the initiation of the next data-collection cycle, if possible. All changes in equipment, sampling procedures, etc. must be documented in the QAPP. If there are no substantive changes to the QAPP, at a minimum, the signature page must be updated and all new signatures obtained. By their signature on the

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document, the individuals are certifying that they agree to be familiar with and to follow all appropriate procedures.

10.2 Documentation for Quality Assurance To ensure that project procedures are documented, each EPA-funded project in the SWQB that generates environmental data is required to have an approved QAPP prior to the initiation of the sample-collection phase of the project. All QAPPs will be prepared according to the EPA Requirements for Quality Assurance Project Plans (QA/R-5, EPA 2001b) and Guidance for Quality Assurance Project Plans (QA/G-5, EPA 2002). All QAPPs will be reviewed and approved by the Program Manager, the Bureau Chief, the SLD Director of QA and the SWQB QA Officer prior to being submitted to EPA Region 6 for final approval. All QAPPs must emphasize that procedures documented will be followed during the project. If any situations require deviation from the documented procedures (such as flooding or inclement weather), this deviation must be thoroughly documented in the field notes and in the resultant report. Although the QAPP specifies the MLs and the QA documentation requirements for each program, all staff members should be encouraged to exceed expectations whenever possible. Whenever changes to procedures can be made to improve the quality of the environmental data generated, these changes should be documented in the QAPP. The QAPP and sampling plan for each project generating environmental data should contain provisions for the collection of QA samples to be submitted to the SLD. These samples are critical for assessing all phases of sample collection and analysis. The results of these samples are used to document the sampling, preservation, and handling techniques and SLD analytical precision. The SLD analytical request forms for the QA replicates must not contain any indication that the samples are QA replicates. All SLD-assigned sample numbers for QA replicate/regular sample pairs are reported to the SLD Director of QA at the end of the calendar year and are used to help minimize analytical problems. Individuals collecting the QA replicates should continually use the analytical results of the samples to refine sample collection, preservation and handling techniques as well as to determine SLD analytical precision. The SWQB management staff will attempt to hire the most qualified applicants for positions within the SWQB. After an individual has been hired by the SWQB, some additional training is required and many types of job-related training are encouraged by individual sections within the SWQB. Most new technical employees will serve a period of apprenticeship with experienced program personnel to guarantee that there will be a continuation of approved procedures and techniques. The apprentice will receive “hands-on” training and will be verbally certified to the Program Manager by the experienced program personnel. The period of this apprenticeship for different tasks will vary greatly according to education, previous experience and the difficulty of the procedures. The Project Leader and Principal Investigator are responsible for thoroughly documenting procedures used during the field portion of the environmental data-generating phase of the project. Any procedures other than those routine procedures specified in the QAPP will be documented on the field sheets and in the field notebooks. All sampling forms will specify the personnel responsible for collecting and processing the sample as well as containing the specific location of the sample, the water body, the data and time of the sample collection. All forms

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must be fully completed so that if personnel resign, the sheets are self-evident to any successors in the program. The generation of environmental data is expensive in terms of field personnel time, travel time, analytical costs, computer usage, etc. No data should be rendered unusable because of sloppy documentation. Program Managers must review the analytical report forms distributed by the SLD, identify any forms that are deficient in documentation and correct the problem by directives to the appropriate Project Leader or Principal investigator. During periods of changeover to newer procedures, the sample collection forms must carefully indicate which procedures were used for the samples. The Project Leader and Principal Investigator are responsible for requesting documentation from the SLD concerning the date and time of sample analysis and the responsible analyst(s). This should be requested in the comments section of the SLD analytical request forms by indicating “Date and time of analysis requested.” The SLD will also indicate the responsible analyst in response to this request.

10.3 Quality Improvement Measures It is the responsibility of all SWQB staff to continually evaluate procedures and techniques used to acquire environmental data and to search for improvements. With falling revenues available for most environmental data generation activities, it is imperative that more efficient and effective techniques be sought. Effective innovations should be acknowledged and shared with other programs. All personnel should be made aware, by the Bureau Chief and Program Managers, that improved quality and increased effectiveness are important SWQB goals.

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11.0 REFERENCES

U.S. District Court for the District of New Mexico. 1997. Forest Guardians and Southwest Environmental Center (Plaintiffs) v. Carol Browner, in her official capacity as Administrator, EPA (Defendant): Joint Motion for Entry of Consent Decree. April 29. Online at www.nmenv.state.nm.us/swqb/CDNM.html. U.S. Environmental Protection Agency (EPA). 1982. Handbook for Sampling and Sample Preservation of Water and Wastewater. EPA 600/4-82-029. Washington, DC. September. ———. 1994. NPDES Compliance Inspection Manual. EPA/300/B-94/014. Office of Enforcement and Compliance Assurance, Washington, DC. September. ———. 1997. EPA Approval Letter from William A. Telliard, Director, Analytical Methods Staff, EPA Office of Water to David Gustafson, Coordinator of Regulatory Affairs, Hach Company for Hach Method 10014, Ultra Low Range Total Residual Chlorine (DPD Method), Adapted from Standard Methods for Examination of Water and Wastewater, U.S. Patent 5,362,650. February 26. ———. 2000a. Guidance for the Data Quality Objectives Process, QA/G-4. EPA/600/R-96/055. Office of Environmental Information, Washington, DC. August. ———. 2000b. Code of Federal Regulations (CFR), Title 40: Protection of the Environment, Chapter 1 – Environmental Protection Agency, Part 136 – “Guidelines Establishing Test Procedures for the Analysis of Pollutants.” ———. 2001a. EPA Requirements for Quality Management Plans, EPA QA/R-2. EPA/240/B-01/002. Office of Environmental Information, Washington, DC. March. ———. 2001b. EPA Requirements for Quality Assurance Project Plans, EPA QA/R-5. EPA/240/B-01/003. Office of Environmental Information, Washington, DC. March. ———. 2002. Guidance for Quality Assurance Project Plans, EPA QA/G-5. EPA/240/R-02/009. Office of Environmental Information, Washington, DC. December. New Mexico Administrative Code (NMAC). 2002. State of New Mexico Standards for Interstate and Intrastate Streams. 20.6.4. New Mexico Water Quality Control Commission. October 11. New Mexico Environment Department/Surface Water Quality Bureau (NMED/SWQB). In Progress. Quality Assurance Project Plan for Water Quality Management Programs. New Mexico Health Department (NMHD). 2003a. Quality Assurance Plan for Chemistry Bureau Services, Revision V. New Mexico Scientific Laboratory Division, Chemistry Bureau. December.

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———. 2003b. Quality Assurance Plan for Biological Sciences Bureau. Scientific Laboratory Division, Biological Sciences Bureau.