Quality Management Plan anagement P lan Q uality Quality Management Plan Minnesota Pollution Control Agency 2013 January 2013

Management

Plan

Quality

Quality Management Plan

Minnesota Pollution Control Agency

2013

January 2013

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Minnesota PCA Concurrences

John Linc Stine, MPCA Commissioner Date

______________________________________________ ___________________________

Michelle Beeman, MPCA Deputy Commissioner Date

_____________________________________________ ___________________________

Shannon Lotthammer Date

Environmental Analysis and Outcomes Division Director

______________________________________________ ____________________________

Todd Biewen Date

Environmental Analysis and Outcomes Division Asst. Director

____________________________________________ ____________________________

Luke Charpentier Date

Quality Assurance Coordinator Supervisor

_____________________________________________ ____________________________

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EPA Region 5 Concurrences

Susan Hedman, Regional Administrator Date

________________________________________________ _____________________

George Czerniak, Acting Director Air and Radiation Division Date

_________________________________________________ _____________________

Kevin Bolger, Regional Quality Assurance Manager Date

_________________________________________________ _____________________

Cheryl Newton, Assistant Regional Administrator for Resources Management Date

_________________________________________________ _____________________

Margaret Guierriero, Director, Land & Chemicals Division Date

__________________________________________________ ____________________

Tinka Hyde, Director, Water Division Date

__________________________________________________ ____________________

Richard Karl Director Super Fund

__________________________________________________ ____________________

U.S. EPA GLNPO Concurrences

Christopher Korleski, GLNPO Director, U.S. EPA GLNPO Date

__________________________________________________ _____________________

Louis J. Blume Quality Assistance Manager U.S. EPA GLNPO Date

__________________________________________________ _____________________

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Table Contents Acknowledgments ................................................................................................................. 1

Acronyms and Abbreviations ................................................................................................. 2

1. Management and Organization ...................................................................................... 4 1.1. Introduction.............................................................................................................................. 4

1.2. Key Definitions.......................................................................................................................... 4

1.3. Scope and Field Of Application .................................................................................................. 5

1.4. Quality Management Policy, Goals and Objectives ..................................................................... 5

1.5. Minnesota Pollution Control Agency Mission Statement ............................................................. 6

1.6. Minnesota Pollution Control Agency Activities and Programs ..................................................... 7

1.7. Minnesota Pollution Control Agency Organizational Structure .................................................... 7

1.8. Environmental Analysis and Outcomes Division ......................................................................... 9

1.9. Minnesota Pollution Control Agency’s Environmental Analysis Outcomes Division’s Organization Chart 9

1.10. Environmental Quality Board .............................................................................................. 12

1.11. The Minnesota Pollution Control Agency Citizens’ Board ...................................................... 13

1.12. Legislative Issues ................................................................................................................. 13

1.13. Legislative Contacts ............................................................................................................ 13

1.14. Staff Roles, Responsibilities and Authorities ......................................................................... 13

1.15. Dispute Resolution .............................................................................................................. 17

2. Quality Systems Components ....................................................................................... 18 2.1. MPCA’s Quality System Description ......................................................................................... 18

2.2. Quality Management Plan Elements ........................................................................................ 19

2.3. Quality System Authorities and Accountability for Managing the Quality System ...................... 20

2.4. Quality Assurance Project Plans .............................................................................................. 21

2.5. Standard Operating Procedures ............................................................................................... 22

2.6. Operational and Strategic Review ........................................................................................... 23

2.7. Performance Management and Quality ................................................................................... 23

3. Personal Training and Qualifications ............................................................................ 24 3.1. Qualifications ......................................................................................................................... 24

3.2. Training .................................................................................................................................. 24

3.3. Training/Trainer Requirements ............................................................................................... 25

3.4. All Staff Training ..................................................................................................................... 25

3.5. Program Specific Training ....................................................................................................... 25

3.6. Employee Performance Evaluations ......................................................................................... 27

3.7. Training Management ............................................................................................................ 27

4. Procurement of Items and Services .............................................................................. 28 4.1. Procurement Roles .................................................................................................................. 28

4.2. Procurement Rules .................................................................................................................. 28

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4.3. Quality Assurance Requirements -Agreements ......................................................................... 30

4.4. When Is A Quality Assurance Project Plan Required ................................................................. 30

5. Document Control and Records .................................................................................... 30 5.1. Record Storage ....................................................................................................................... 30

5.2. Record Control ........................................................................................................................ 31

5.3. External File Review ................................................................................................................ 32

5.4. Technical Guidance Documents and Factsheets ........................................................................ 33

5.5. Quality Assurance documents ................................................................................................. 34

5.6. Planning for a New Document ................................................................................................. 34

5.7. Creating a Factsheet ............................................................................................................... 34

5.8. Special Considerations for Legislative Factsheets ..................................................................... 34

6. Information Management ............................................................................................ 34 6.1. Information System Integration ............................................................................................... 35

6.2. Data Quality and Data Integrity .............................................................................................. 35

6.3. MPCA’s Green Data Program .................................................................................................. 35

6.4. Databases .............................................................................................................................. 36

6.5. Information Strategy .............................................................................................................. 40

6.6. Data Quality Audits ................................................................................................................ 41

7. Quality Planning .......................................................................................................... 42 7.1. Minnesota Pollution Control Agency Strategic Plan .................................................................. 42

7.2. The Minnesota Pollution Control Agency’s Strategic Plan: High Level Planning.......................... 42

7.3. Workplans: Program, Individual Level...................................................................................... 43

7.4. Program Specific Planning ....................................................................................................... 43

7.5. MPCA Business Plan Program Specific Planning ....................................................................... 43

7.6. Data Quality Objectives .......................................................................................................... 44

7.7. Quality Assurance Project Plans .............................................................................................. 47

7.8. Data Quality Improvement Planning ....................................................................................... 49

7.9. Environmental Performance Partnership Agreement ................................................................ 49

7.10. Water Quality Planning and Management using a Watershed Approach .............................. 51

8. Quality Implementation of Work Processes .................................................................. 54 8.1. MPCA Quality Implementation ................................................................................................ 55

8.2. The Implementation of Quality Assurance Plans and Work Plans .............................................. 55

8.3. Standard Operations and Procedures (SOPs) ............................................................................ 55

8.4. Sampling Guidance ................................................................................................................. 56

8.5. Policy Documents .................................................................................................................... 56

9. Quality Assessment and Response ............................................................................... 56 9.1. Management System Reviews (Technical Audits) ..................................................................... 56

9.2. Audits and Surveillance ........................................................................................................... 58

9.3. Data Quality ........................................................................................................................... 59

9.4. Data Quality Assessment ........................................................................................................ 59

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9.5. Laboratory Audits ................................................................................................................... 59

9.6. Laboratory Performance Evaluation ........................................................................................ 61

9.7. Product and Service Evaluations .............................................................................................. 62

9.8. Peer and Technical Review ...................................................................................................... 63

9.9. Data Evaluation ...................................................................................................................... 63

9.10. Site Assessments ................................................................................................................. 64

9.11. Reporting ........................................................................................................................... 64

10. Quality Improvement ................................................................................................... 65 10.1. Background ........................................................................................................................ 65

10.2. Continuous Quality Improvement Process ............................................................................ 66

10.3. Six Sigma/Enterprise Lean ................................................................................................... 66

10.4. Water Management Continuing Planning Process ................................................................ 67

10.5. Program Evaluation ............................................................................................................ 68

10.6. Field Performance Audit ...................................................................................................... 68

10.7. Minnesota Pollution Control Agency Laboratory Quality Control and Data Policy .................. 68

References .......................................................................................................................... 71

Figures

Figure 1 QMP Umbrella .....................................................................................................................4 Figure 2. MPCA Management Organization Chart ...............................................................................8 Figure 3. MPCA Regional Offices ...................................................................................................... 12 Figure 4 Components ....................................................................................................................... 18 Figure 5 MPCA’s Quality System ....................................................................................................... 19 Figure 6. MPCA Green Data Program ............................................................................................... 36 Figure 7. Relationships and planning horizons .................................................................................. 42 Figure 8 The MPCA Monitoring – Data – Information Cycle ............................................................... 51 Figure 9 Intensive Watershed Monitoring Map ................................................................................ 52 Figure 10. The Audit Corrective Action Process ................................................................................. 57 Figure 11. Six Sigma DMAIC diagram ................................................................................................ 66

Tables Table 1. QMP Contributors ................................................................................................... 1 Table 2. Acronyms and Abbreviations .................................................................................... 2 Table 3. MPCA Quality Assurance Coordinator Staff ............................................................ 16 Table 4. MPCA Programs Addressed in the Business Plan ..................................................... 44 Table 5. MPCA Programs That Require QAPPs ...................................................................... 47

Quality Management Plan 2013 • January 2013 Minnesota Pollution Control Agency

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Acknowledgments This revision of the Minnesota Pollution Control Agency’s (MPCA’s) Quality Management Plan (QMP) was completed with assistance from MPCA staff and management. A special thank you to the following staff and management for their contribution:

Table 1. QMP Contributors

Alice Clark Kellie Garvin

Beth Aschinger Kim Austrian

Bob Day Kim DeVeau

Chris Johnson Kirk Koudelka

Colleen Naughton Kris Parson

Dennis Fenlon Lyle Mueller

Roger Fisher Luke Charpentier

Doug Day Matt Lindon

Doug Wetzstein Mary Jean Fenske

Ed Meyer Randy Hedegaard

Frank Kohlasch Steve Thompson

Glenn Skuta Sue Henry

Jeff Lewis Tad Schindler

Jess Richards Todd Biewen

Mark Schmitt

Key Quality Staff employees that have been instrumental in this revision include Matt Lindon, Luke Charpentier, Bill Scruton and Roger Fisher.

A specific thank you to the U.S. Environmental Protection Agency (EPA) Region 5 Quality Assurance (QA) Manager Kevin Bolger for his leadership and for providing continuous peer support to the GLNPO QA Manager.


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Acronyms and Abbreviations

Table 2. Acronyms and Abbreviations

AIRS Aerometric Information Retrieval System

AQS Air Quality Subsystem

BID Basin Information Document

BPA Bisphenol A

CA Corrective Actions

CAS Chemical Abstract Society

CCCS Continuing Calibration Check Standard

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CFR Code of Federal Regulations

CLP Closed Landfill Program

COC Chain of Custody

CWA Clean Water Act

CWP Clean Water Program

DMADV Define, Measure, Analyze, Design, Validate

DMAIC Define, Measure, Analyze, Improve, Control

DMR Discharge Monitoring Report

DMR-QA Discharge Monitoring Report – Quality Assurance

DNR Department of Natural Resources

DOD Department of Defense

DOER Department of Employee Relations

DQA Data Quality Assessment

DQO Data Quality Objectives

EAO Environmental Analysis & Outcomes

ECOS Environmental Council of States

EDA Environmental Data Access

EDMS Environmental Data Management System

EnPPA Environmental Performance Partnership Agreement EnPPA

EPA Environmental Protection Agency

GC/MS Gas Chromatography/Mass Spectrometry

GIS Geographic Information System

GLNPO Great Lakes National Program Office

GUI Graphic User Interface

GRLI Great Lakes Restoration office

GWMAP Groundwater Mapping and Assessment Program

HBV Health Based Value

HRL Health Risk Limit

HRS Hazard Ranking System

HT Holding Times

IAR Integrated Assessment Report

IGWIS Integrated Groundwater Information System

IP Information Protocol

IRDMIS Installation Restoration Data Management Information System

ISO Information Systems Office

LAN Local Area Network

LIMS Laboratory Information Management System

LM Laboratory Manager

LUST Leaking Underground Storage Tank

MAP Monitoring and Assessment Planning

MAPS Minnesota Accounting and Procurement System

MCES Metropolitan Council Environmental Services

MCL Maximum Contact List

MDH Minnesota Department of Health

MDL Method Detection Limits

MERLA Minnesota Environmental Response and Liability Act

MPCA Minnesota Pollution Control Agency


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MS4s Municipal Separate Storm Sewer Systems

MSR Management Systems Review

NAMS National Air Monitoring Station

NATTS National Air Toxics Trends Site

NCORE National Core Monitoring Network

NEMI National Environmental Methods Index

NEPPS National Environmental Performance Partnership System

NFG National Functional Guidelines

NPAP National Performance Audit Program

NPDES National Pollutant Discharge Elimination System

OSHA Occupational Safety and Health Administration

P2 Pollution Prevention

PDF Portable Document Format

PE Performance Evaluation

PM Project Manager

PM2.5 Particulate Matter (2.5 micron)

PQL Practical Quantification Limit

PT Proficiency Test

QA Quality Assurance

QAC Quality Assurance Coordinator

QA ID QA Identification

QAC Quality Assurance Coordinator

QAM Quality Assurance Manual

QAPP Quality Assurance Project Plan

QAPrP Quality Assurance Program Plans

QC Quality Control

QMP Quality Management Plan

RCRA Resource Conservation and Recovery Act

RFP Request for Proposal

RFRA Response for Requested Action

RL Reporting Limit

RP Responsible Party

S&E Supplies and Expenses

SAP Sampling and Analysis Plan

SAS Statistical Analysis System

SDT Strategic Directions Team

SDWP Safe Drinking Water Program

SLAMS State/Local Air Monitoring Station

SMOA Superfund Memorandum of Agreement

SOPS Standard Operating Procedure

STORET Storage and Retrieval

TALES Tanks and Leaks

TMDL Total Maximum Daily Load

TSCA Toxic Substances Control Act

UMRB Upper Mississippi River Basin

URL Uniform Resource Locator

US EPA U.S. Environmental Protection Agency

UST Underground Storage Tank

VIC Volunteer Investigation and Cleanup

WAN Wide Area Network

WP Water Pollution

WS Water Supply


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1. Management and Organization

1.1. Introduction

The Minnesota Pollution Control Agency’s (MPCA) Quality Management Plan (QMP) describes the quality management structure and processes used to maintain a Quality Management System consistent with U.S. Environmental Protection Agency (EPA) requirements. The QMP is updated and submit for EPA approval every five years. MPCA’s QMP is based on the national consensus standard, Specifications and Guidelines for Quality Systems for Environmental Data Collection and Environmental Technology Programs ANSI/ASQC E4-1994 and: Guidance on Systematic Planning Using the Data Quality Objectives Process, EPA QA/G-4, February 2006 (EPA/240/B-06/001). New Quality standards from EPA should be finalized in 2013 the standards will be incorporated into MPCA’s QMP in future revisions.

1.2. Key Definitions

Quality Assurance

It is an integrated system of management activities involving planning, implementation, assessment, reporting, and quality improvement to ensure that a process, item, or service is of the type and quality needed, and expected, by the customer.

Quality Control

Quality Control (QC) is the overall system of technical activities that measures the attributes and performance of a process, item, or service against defined standards to verify that they meet the stated requirements established by the customer; operational techniques and activities that are used to fulfill requirements for quality.

Quality Assurance Program Plan

Quality Assurance Program Plan (QAPrP) are used to describe details that are specific to a Program, or Division, when the QMP is too general to encompass the unique circumstances for all Programs. The appropriate level of planning will be determined within the Program. For some Programs, a Quality Assurance Program Plan (QAPrP) may be sufficient to be utilized in lieu of a QAPP

Quality Assurance Project Plans

Quality Assurance Project Plans (QAPPs) document the planning, implementation, and assessment procedures for a particular project, as well as any specific Quality Assurance (QA) and QC activities. It integrates all the technical and quality aspects of the project in order to provide a "blueprint" for obtaining the type and quality of environmental data and information needed for a specific decision or use. All work performed or funded by EPA that involves the acquisition of environmental data must have an approved Quality Assurance Project Plan.

Figure 1 QMP Umbrella


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Data quality objectives

Environmental data collected should be of adequate quality and quantity to support intended assessment or regulatory decisions, and when necessary be legally defensible. Data Quality Objectives (DQOs) are used in the planning phase of all agency Data generation activities in the capacity that defined objectives shall be identified before sampling goes forward. The Guidance for the Data Quality Objectives Process (2006) and EPA’s QA/G-4 is used as appropriate for the development of DQOs by the agency. In many situations, regulatory criteria and standards limits are the basis for environmental decisions. In these situations, the appropriate planning document (i.e. QAPrP, QAPP), or standard operating system (SOP) should state regulatory limits are the driving force for Data Quality Objectives.

1.3. Scope and Field Of Application

The MPCA’s QMP applies to all areas of the agency’s work. The MPCA’s quality system encourages staff to resolve problems in a timely manner calling upon QA staff as needed to solve issues they are unable to solve at their level. Staff are responsible for planning, executing, documenting, and reviewing all work performed to ensure that it conforms to the DQOs that were established for the program, project, and services on which the staff are working and that were documented in the applicable QAPrP or QAPP. Supervisors assist staff to ensure all facets of the problem are considered and the best options used. The QACs are responsible for writing quality-related policies, which are then incorporated by staff into their Work Plans and QAPPs and advising staff and management of issues with chemistry or quality assurance problems that arise. Each MPCA environmental monitoring program’s work follows an approved QAPP, Work Plan, and as needed SOPs, which are part of the QMP.

1.4. Quality Management Policy, Goals and Objectives

Quality management policy

Most policies specific to programs or projects are included in QAPrPs and QAPPs. The MPCA has general QA/QC policies that apply across the agency. These Policies include:

Programs generating, using, or requiring the collection of environmental data will be consistent with the intentions outlined in the agency QMP, policies, and SOPs.

The data quality objectives for generating new environmental data will be determined prior to Data generation activities, so that appropriate resources and QA/QC methods can be applied to ensure a level of data quality commensurate with the intended use(s) for the data.

Effective QA Project Plans and SOPs shall be developed and implemented as required by the MPCA organization responsible for implementing the project.

All environmental data generated by the agency should be of known and documented quality, as defined by pre-established DQOs or existing regulatory levels. DQOs need to be clearly stated with each individual project, but are often predetermined by regulatory criteria and action levels within similar Programs. If the DQO formal process is needed it should be implemented consistent with EPA’s Guidance for the DQO Process, August 2006, Guidance on Systematic Planning Using the Data Quality Objectives Process, EPA QA/G-4, February 2006 (EPA/240/B-06/001) or an equivalent document.

Quality of existing data is addressed by the MPCA’s Green Data Program Section 6.3

MPCA’s QA/QC Unit shall act as the environmental liaison for quality assurance information to and from Region 5 EPA.


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Graded approach

The MPCA uses a graded approach to its quality systems allowing each program or project to shape the quality requirements to meet the quality objectives and needs of the program. The graded approach establishes QA and QC requirements based on:

1. importance of the work 2. available resources 3. the unique needs of the program 4. consequences of potential decision errors

Quality management goals and objectives

The MPCA ability to make quality decisions depends heavily on the quality of information used to make those decisions. If those data are not of adequate quality to support their intended use, then subsequent decisions will suffer commensurately. Environmental data are used for setting priorities; establishing strategic direction; targeting inspections; measuring compliance; identifying enforcement actions; measuring progress and trends; certifying laboratories; and for many other uses. Environmental data are critical because they can affect a program’s direction and emphasis, determine whether an enforcement case can be successful, or dictate which of several cleanup options will be implemented at a contaminated waste site. The consequences of poor data (i.e., do not meet user requirements) is that individual and collective decisions could lead to wrong conclusions, inefficient use resources, or decisions that could harm the public. The goal of the MPCA’s Quality System is maintain a high standard of QA/QC across the agency in order to avoid occasions where the environmental data collected fall short of meeting the stated DQOs for a site or program.

It is essential to the MPCA’s mission that the quality of work we perform be sufficient to enable us to make responsible environmental decisions. A fundamental component of quality work is the collection of data that are scientifically and legally defensible.

1.5. Minnesota Pollution Control Agency Mission Statement

The MPCA mission is to work with Minnesotans to protect, conserve and improve our environment and enhance our quality of life. To accomplish this mission the agency works on the following visions:

1. Minnesotans and MPCA take actions to protect our land, water and air 2. Clean and clear air supports healthy communities and a strong economy 3. Clean water supports aquatic ecosystems, healthy communities and a strong economy 4. The MPCA will demonstrate excellence in operations

These visions are detailed in the MPCA Strategic Plan and are discussed in Section 7 Quality Planning or at http://www.pca.state.mn.us/index.php/view-document.html?gid=5661.

It develops and enforces laws and regulations that protect the environment. It implements prevention and assistance programs. The MPCA also collaborates with business groups, environmental organizations, educational institutions, other branches of state and local units of government, the EPA, and the public at large to accomplish its mission.

http://www.pca.state.mn.us/index.php/view-document.html?gid=5661


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1.6. Minnesota Pollution Control Agency Activities and Programs

The MPCA has numerous programs targeting specific environmental areas (Table 3). These programs vary in size and scope and all have QA/QC policies to insure quality objectives are met. Managing the QA/QC policies is the responsibility of: Program staff, MPCA management, and MPCA QA/QC staff. All have the responsibility to ensures that adequate QA/QC is adhered to in all MPCA programs.

Programs that work under QAPrPs

In the past many programs and projects have had worked under specific QAPrPs or other QC guidance. These plans and guidance documents change as programs and projects progress. The current list of MPCA programs that have QAPrPs includes: Water, TSCA, Tanks, RCRA, NPDES, Surface Water, Air Toxics/2.5/Metals, Biological Monitoring, Sediment and GLRI. A complete and more detailed list is in section 7.7 Table 5. MPCA Programs That Require QAPPs.

1.7. Minnesota Pollution Control Agency Organizational Structure

Each of the divisions and offices is headed by a manager responsible for the quality of work planned and performed under their guidance (Figure 3). Similarly, each division and office has sections with managers overseeing the development of work products specific to their areas of responsibility. Each section has multiple units, each with a supervisor who is responsible for the quality of work planned and performed by the unit MPCA’s program organization chart http://www.pca.state.mn.us/index.php/view-document.html?gid=107. The supervisor is charged with overseeing staff activities to ensure daily work is being accomplished. MPCA staff is encouraged to seek assistance from their supervisors when confronted with difficult decisions.

The MPCA staff frequently work in teams, many of which have leaders who are liaisons with the regulated community and who coordinate team activities. Other members of the team may include technical and field staff. For example, in site remediation programs, a project leader coordinates the team activities and is supported by a Hydrologist or Soil Scientist as a technical expert and a Pollution Control Specialist who serves as a field expert and on-site inspector.

The MPCA is organized both geographically and programmatically (Figure 4). The geographic structure is designed to focus on local problems and provide program services and support at the local level. Normal routine program decisions and resource allocation are made by appropriate staff and managers within each division as delegated by the Board or Commissioner, with ultimate operational reportability to the Deputy Commissioner. Strategic issues that involve new or changing directions fall under the guidance of Assistant Commissioners who have media (air, water, and land) responsibilities.



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The MPCA has several management teams charged with different duties. The Agency Steering Committee is made up of Commissioners, Division Directors, and Managers. This committee meets monthly and makes decisions on priorities and strategic directions. The agency has created management teams to address issues that cross structural units. These teams include:

Information Management Team

Human Resources Management Team

Fiscal Management Team

CIMT (Continuous Improvement Management Team)

Environmental Results Management Team

Business Management Team

These teams develop policy and build agency-wide acceptance for solutions that ensure consistency in conducting agency business. The MPCA serves Minnesota by examining the quality of the state's environment, developing rules that protect the public's health and the environment, and helping local government, industry, and individuals meet their environmental responsibilities.

Figure 2. MPCA Management Organization Chart

http://intranet.pca.state.mn.us/index.php/component/content/article/73-agency-operations/management-teams-and-media-forums/425-continuous-improvement-management-team


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1.8. Environmental Analysis and Outcomes Division

The MPCA Environmental Analysis & Outcomes (EAO) Division currently conducts a variety of monitoring activities that supports the agency’s overall mission of working with Minnesotans to protect, conserve, and improve our environment. To successfully address problems, the agency staff need reliable information about the status of resources, potential and actual environmental threats, options for addressing the threats, and data on how effective management actions have been. The MPCA’s monitoring efforts are focused on providing this information. Overall, the MPCA is striving to generate data to assess, restore, and protect the integrity of Minnesota’s environment.

Staff in the Environmental Analysis and Outcomes Division monitor and evaluate the physical, chemical and biological conditions of Minnesota’s environment. This information is used to:

identify environmental threats and impacts to human and ecosystem health

lead strategic planning for the agency

help set environmental goals and measure progress in achieving them

establish standards

conduct risk assessments and effluent limits in support of regulatory programs

make data accessible to agency leadership, staff, stakeholders and citizens

Examples of programs and activities conducted in the division include:

Biological Monitoring

Citizen Lake Monitoring

Citizen Stream Monitoring

Air Emissions Risk Analysis

Environmental Information Report

Environmental Data Access

Environmental Bulletin

1.9. Minnesota Pollution Control Agency’s Environmental Analysis Outcomes Division’s Organization Chart

Staff in the Environmental Analysis and Outcomes Division monitor and evaluate the physical, chemical and biological conditions of Minnesota’s environment. This information is used to:

identify environmental threats and impacts to human and ecosystem health

lead strategic planning for the agency

help set environmental goals and measure progress in achieving them

establish standards

conduct risk assessments and effluent limits in support of regulatory programs

make data accessible to agency leadership, staff, stakeholders and citizens


Biological Monitoring

Citizen Lake Monitoring

Citizen Stream Monitoring

Air Emissions Risk Analysis

Environmental Information Report

Environmental Data Access

Environmental Bulletin


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http://www.pca.state.mn.us/index.php/view-document.html?gid=39.

Industrial Division

The Industrial Division operates the agency’s core regulatory programs that work with larger industrial facilities to ensure they are in compliance with air quality, water quality and hazardous waste regulations.


Air permitting

Water permitting

Waste management

Above ground storage tanks

Underground storage tanks

MPCA’s Industrial Divisions organization chart http://www.pca.state.mn.us/index.php/view-document.html?gid=5667.

Municipal Division

The Municipal Division works with cities and towns to ensure proper management of wastewater, stormwater, and solid waste to help protect the environment and citizens. Work includes technical assistance, development of rules and policy, permitting, and compliance and enforcement.


Stormwater

Wastewater

Land Treatment

MPCA’s Municipal Divisions organization chart http://www.pca.state.mn.us/index.php/view-document.html?gid=5668.

Watershed Division

The MPCA Watershed Division delivers most environmental programs, products and services for smaller, dispersed sources of pollution such as small cities, businesses, and individuals. The Watershed Division has offices located across the state.

Many water quality programs are based in this division. Specific programs include feedlots, basin management, landfill operations, and other programs targeting nonpoint source pollution. Additional information about some of these activities can be found in the links below.

MPCA’s Watershed Divisions organization chart http://www.pca.state.mn.us/index.php/view-document.html?gid=5669.

Remediation Division

Remediation is the process of cleaning up pollution in the soil, water, or air from an accidental spill or from polluting activities that occur over a long period of time. The MPCA has many programs that clean up pollution ranging from Voluntary Investigation and Cleanup (VIC) to the Emergency Response Team. The Brownfields Program cleans up abandoned land sites contaminated by industry so they can be safely redeveloped. Below are helpful links to remediation programs.

MPCA’s Regional Divisions organization chart http://www.pca.state.mn.us/index.php/view-document.html?gid=5670.





http://www.pca.state.mn.us/index.php/waste/waste-and-cleanup/cleanup-programs-and-topics/cleanup-programs/cleanup-programs.html



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Resources Management and Assistance Division

The Resource Management and Assistance Division emphasizes the use of voluntary, innovative environmental approaches, including pollution prevention, technical and financial assistance, and environmental education, to develop comprehensive system-based approaches to environmental problems and supports the agency’s information and knowledge management systems.

The Prevention and Solid Waste Management Section works to create successful, environmentally sustainable businesses through product stewardship, market development, design for the environment (DfE), preventing pollution at the source, reducing toxicity and waste in products and product uses, and helping facilities operate in compliance with regulations. The section also offers the One-Stop Program, in partnership with the Department of Employment and Economic Development, helping new and expanding businesses navigate through environmental regulations and identify pollution prevention opportunities.

The Community and Business Assistance Section works to create stronger and healthier communities by working with community decision makers, educators, and other leaders to educate and inform on environmental issues. The section promotes eco-industrial development, green buildings, and replies upon policy initiatives and financial incentives to promote partnerships that advance the agency’s environmental goals and objectives. This section includes the staff in the Business Assistance Unit that answers questions from regulated parties and citizens about air quality, water quality, solid and hazardous waste and storage tank regulations, and help them identify opportunities to prevent pollution. The Section supports the sustainable communities’ network, the Living Green Expo, and major conferences and events.

Training Events Calendar

Small Business Assistance Program

SEEK: An Interactive Directory of Environmental Education Resources

Solid waste management

Environmental Review MPCA’s Prevention and Assistance Divisions organization chart http://www.pca.state.mn.us/index.php/view-document.html?gid=5671.

Operations Division

The MPCA’s Operations Division works to enable management of resources (people, dollars, and knowledge) toward the Agency's current and future priorities by providing a framework and message for linking resources to the vision. The operational functions of this division serve as connections or relationship-building throughout the Agency and enable leadership to obtain and share knowledge about and direct and communicate the Agency-wide management resources.

Operations Division http://www.pca.state.mn.us/index.php/view-document.html?gid=5672.

Minnesota Pollution Control Agency Regional Offices

The MPCA has regional offices in eight cities throughout greater Minnesota. The main office is in St. Paul with regional offices in Brainerd, Detroit Lakes, Duluth, Mankato, Marshall, Rochester, and Willmar.

http://www.pca.state.mn.us/index.php/about-mpca/events-and-training/index.html




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Figure 3. MPCA Regional Offices

1.10. Environmental Quality Board

The mission of the Environmental Quality Board (EQB) is to lead Minnesota environmental policy by responding to key issues, providing appropriate review and coordination, serving as a public forum and developing long-range strategies to enhance Minnesota's environmental quality. The EQB consists of a Governor's representative (by law the board chair), nine state agency heads and five citizen members. A key connection with the MPCA is through the EQB’s oversight role in environmental review. EQB also works with


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the MPCA on broad policy issues such as the state water plan. EQB staff are housed in the MPCA St. Paul building.

1.11. The Minnesota Pollution Control Agency Citizens’ Board

Major policy issues or decisions of particular environmental significance are taken before the MPCA Citizens’ Board for discussion and resolution in a public forum. The MPCA Commissioner serves on the MPCA Citizens’ Board, which is otherwise comprised of citizens appointed by the Governor.

The MPCA Citizen Board sets agency policy and direction and takes action on certain other significant or controversial issues. Under the authority of delegations from the MPCA Citizens’ Board, the commissioner directs the day-to-day work of the agency's staff of approximately 950 staff.

1.12. Legislative Issues

Each year the MPCA works with the Governor's Office, the State Legislature, and other partners to ensure that legislation affecting Minnesota's environment effectively achieves improvements in the state’s land, air, and water quality.

During each legislative session, agency staff routinely provide reports, testimony, suggestions, cost estimates and other information. The agency often works with specific legislators on key initiatives and provides factsheets and reports on legislative issues to legislators and other stakeholders on specific issues, which are available through the MPCA webpage. Contacts for more detailed information are provided in each factsheet.

1.13. Legislative Contacts

During the legislative session, many issues and initiatives involve the MPCA, and key staff members have been identified as primary contacts on specific topics. The legislative contact at MPCA works directly with management and technical staff as needed at the MPCA to answer questions posed by the legislature, follows up on bills moving through the houses, and track issues of interest to the Agency during the session.

1.14. Staff Roles, Responsibilities and Authorities

Quality Assurance Director

The Environmental Analysis and Outcomes Division Director has the ultimate responsibility for QA at the MPCA. Although he/she does not bear the title of QA Manager, he/she serves this function through ultimate oversight of MPCA quality activities, most of which is conducted within the Environmental Analysis and Outcomes (EAO) Division through the Environmental Data Quality Unit, and through this unit, throughout the MPCA. The EAO Division Director gives final approval on any issues dealing with other state and federal Agencies, major issues requiring an approval, and major policy documents. The EAO Division Director is the final arbitrator for any large-scale quality assurance issues.

Environmental Data Quality Manager

The Environmental Data Quality Manager is responsible for all QA work for MPCA programs and sites. The EDQ Manager is the QA Manager for the MPCA and therefore, reviews issues raised by the QA Supervisor, QA staff, or other managers and staff throughout MPCA making decisions on resources and Agency wide policy decisions. The QA Manager is the final decision maker for any contested QA related activity or issues that arise for site work or internal issues and works with the EAO Division Manager (who is overall in charge of quality assurance) for highly contentious issues, possible legal issues involving quality assurance decisions


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or policy. The QA Manager is not involved in day to day operations at the staff level or with normal laboratory oversight, but is available to meet with any laboratory or consultant with a concern. The QA Manager receives daily check-ins and directly rates the QA Supervisor.

Quality Assurance Coordinators Supervisor

The MPCA QA supervisor is located in the St. Paul office. The QA Supervisor oversees the day to day QA efforts of the QACs. The QA Supervisor works with the QACs, Sections, and Units across the MPCA to ensure a balance of QA support for Agency programs. The QA Supervisor meets with external agencies and parties as needed to assist with QA programmatic or policy issues. More on the QA supervisor accountability and management role can be found in Section 0.

Quality Assurance Coordinators

The QAC’s are responsible for day-to-day quality operations across MPCA programs. This includes reviews of QAPPs, training of staff, interactions with EPA and other agencies involved in different aspects of programmatic and site work, and often answer questions from staff and consultants on environmental chemistries. As part of this, the QAC’s are responsible for the effectiveness of the MPCA’s Quality System. The QAC’s will also ensure the development and implementation of corrective actions in conformance with external and/or internal assessments. QACs work directly with the QA Supervisor when contested issues or new and emerging questions arise to ensure consensus when needed from the unit and unity of effort in the QA approach within the MPCA. The QACs are the initial contact for all staff with questions dealing with chemistry and often work on a wide variety of projects. When the same question arises often or an issue comes up that will require a decision by management this issue is put on the MPCA QA website in either the frequently asked questions or written into a policy approved by the Agency for use by the public and State. These policies are used to ensure laboratories understand the requirements of MPCA for data being used by the Agency for decision making. The website can be found at http://www.pca.state.mn.us/index.php/about-mpca/mpca-overview/agency-strategy/mpca-quality-system.html?menuid=&missing=0&redirect=1.

All coordinators are located in the St. Paul MPCA and report to the QA supervisor. This group meets regularly on a variety of quality issues including

Quality Documentation

Field QA

Lab QA

Quality Audits

They support the QA needs across the agency as well as assist outside groups. The QACs are the initial contact for all staff with questions dealing with chemistry and often work on a wide variety of projects. More on the QACs accountability and managing of QA can be found in section.

Great Lakes Restoration Quality Assurance Coordinator

The Minnesota GLRI QAC is a temporary position funded by the EPA GLRI. This position independently acts as the Office of the Great Lakes (OGL) liaison between MPCA, EPA other States, Tribes, Canada and other Federal Agencies on matters of quality. This position is responsible for developing and maintaining MN GLRI Funded Quality Management Plans, and coordination of quality management efforts.

Roles and Responsibilities of the GLRI QAC are specific to GLRI funded projects and include:

Acts as a liaison between the organization and GLNPO’s Quality Staff on matters of quality policy.

Develops a QMP and revises it as necessary.

http://www.pca.state.mn.us/index.php/about-mpca/mpca-overview/agency-strategy/mpca-quality-system.html?menuid=&missing=0&redirect=1



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Reviews QAPPs for all projects, work assignments, grants, cooperative agreements, and inter-agency agreements involving data acquisition, data generation, and/or measurement activities that are performed on behalf of EPA.

Approves all QAPPs for implementation in all applicable projects, work assignments, grants, cooperative agreements, and inter-agency agreements performed on behalf of EPA and where specific approval of QAPPs has been delegated to a responsible EPA official, QAPPs for concurrence.

Coordinates the correction of deficient QAPPs with the PO and his/her management, and assures through appropriate procedures (e.g., contract, financial assistance) that no Data generation operations commence before a QAPP is approved.

Reviews, at the specific technical direction of the GLRI Quality Manager, QAPPs and other QA related planning documents, such as sampling and analysis plans, DQO specifications, etc., to determine if the proposed QA approach documented is adequate for the work planned, based on explicit evaluation criteria provided by the EPA (the reviews should identify specific technical deficiencies in the QAPP to the attention of EPA).

Ensures that all laboratory, field, or office personnel involved in environmental information collection have access to any training or QA information needed to be knowledgeable in QA requirements and protocols.

Ensures that audits/reviews are accomplished to assure adherence to approved quality system documentation and to identify deficiencies in QA/QC systems.

Ensures that adequate follow-through actions are implemented in response to audit/review findings.

Identifies problems and advises on required management-level corrective actions to Director and Management Team.

Implements peer review component of quality system.

Provision of technical support.

Assists staff scientists and project managers in developing quality system documentation and in providing answers to technical questions.

Ensures that all GLRI environmental information collection activities are covered by appropriate quality system documentation (e.g., QAPPs).

Ensures that sampling and analytical methods for GLRI project operations are well documented through Standard Operating Procedures (SOPs).

Assists in determining for each project, the need for, type, and frequency of performance evaluation and reference samples.

Assists in solving QA-related problems at the lowest possible organizational level.

Development, review and approval of QA products.

Tracks the status of all GLRI quality system documentation using GLNPO’s QA Track Database to be provided.

Build an inventory tracking system for all GLRI QA documentation.

Monthly status of QA activities report sent to Regional and GLNPO QA managers by the first Thursday of each month.

Participate in a monthly call with all responsible parties to provide updates on State GLRI projects.

As the QA lead meet/conference call all the team members in the project for updates weekly.

Develops a QA Annual Report and Work-plan for the GLNPO Director that documents the total amount of projects that require quality documentation and the status of the approval and implementation of the required quality documents. Additionally the report should provide a work plan and budget for QA activities the following year and discussions on the status of


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Quality in their organizations using the Stages of Quality Metric, and assessments of how to improve the program. The report should be provided by December 15, of each year.

Table 3. MPCA Quality Assurance Coordinator Staff

Staff Member Staffing FTE

Programs Responsibilities

Luke Charpentier

1 Supervisor All program QC oversight, performance management within the Agency, work with external agencies, reporting.

Sandy

McDonald

Bill Scruton

2.0

RCRA,

Superfund Solid

Waste, Tanks

QAPP Review, Policy Writing, QA Training, Public Contact for QA,

Laboratory Contracting/Auditing, Data review/validation

Dennis Fenlon 1.0 Air Quality

Air Monitoring Project Plan Review, QAPP Writing, Air Laboratory Quality

Assurance Management, Coordinate Quality Assurance Field

Operations, Data Validation

Robert Derfus 1.0 Air Quality State and Industrial Site Audits

Roger Fisher 1.0 Water Quality QAPP Writing and Review, Policy Writing, QA Training

Matt Lindon 1.0 GLRI QAPP Writing and Review, Policy Writing, QA Training

Management

Management assures that applicable element of the QMP are understood and are implemented at the appropriate level. Each of the divisions and offices is headed by a manager responsible for the quality of work planned and performed under their guidance. Similarly, each division and office has sections with managers overseeing the development of work products specific to their areas of responsibility. Each section has multiple units, each with a supervisor who is responsible for the quality of work planned and performed by the unit. The supervisor is charged with overseeing staff activities to ensure daily work is being accomplished. MPCA staff are encouraged to seek assistance from their supervisors when confronted with difficult decisions.

MPCA management supports the QACs in their work and the program staff through mediating issues that arise on site and being supportive of the QA program at the MPCA. Management sends their staff to QA training as it becomes available to staff and often will send questions asked at unit meetings or forums to the QACs to be handled. Management participates in the construction of the QMP for the Agency and supports the program through staffing and money available for laboratory and/or site visits when needed. Further, management is available to work across agencies and with EPA when questions arise needing clarification or approval of QAC answers.

Project managers and staff

Project managers and staff work directly with the QACs on program and project QAPPs. They also have day to day contact with the QACs on site questions and data analysis. They participate in classes and seminars given by the QACs to sharpen their QA and analytical chemistry skills used in data interpretation and understanding laboratory QC reports. The PMs and Staff are key to the QA system as they are often the ones who discover a problem as it emerges and bring the laboratory or site issue to the attention of the QA staff for follow up. Nearly all laboratory problems are initially raised by project staff who notice QC limits or procedures that do not match those they have learned in classroom sessions or from training they have received. Further, the PMs and staff make site decisions based on the data and are keenly interested in ensuring the data is of acceptable quality for the decisions being made. This gives them a vested interest in the QA system at the MPCA.


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Program staff

The MPCA staff frequently work in teams, many of which have leaders who are liaisons with the regulated community and who coordinate team activities. Other members of the team may include technical and field staff. For example, in site remediation programs, a project leader coordinates the team activities and is supported by a Hydrologist or Soil Scientist as a technical expert and a Pollution Control Specialist who serves as a field expert and on-site inspector.

1.15. Dispute Resolution

Implementation of quality management activities may sometimes result in disagreements among involved parties. When these disputes occur, the individual involved must document the situation and present them to management. Resolution will be sought at the lowest management level. MPCA staff will attempt to resolve the dispute through discussion and negotiation.

A committee, consisting of 5 to 10 staff with relevant experience and expertise may be formed as needed to address specific quality issues. The committee will identify the problem, gather information, examine the courses of action available, define the criteria for evaluation of possible solutions to the problem, evaluate the possible solutions, and decide on the best course of action. It will write a memorandum outlining the group’s decisions and proposed solution and submit it to management for review and consideration. If management adopts the proposal, the committee is discharged. If not, the committee reconvenes to investigate possible alternate solutions.

If needed, final resolution will be made by MPCA directors when negotiations do not resolve the issue. Management insures that disputes are resolved in a timely manner so that work schedule and performance are not impeded. When quality assurance or laboratory issues arise, the first attempt is to solve the problem within the program or by negotiations involving the QACs. If this fails, the QA supervisor can become involved as required. The QA Manager is the last step prior to involvement of the Division Directors for major issues that cannot be resolved. The majority of issues are solved at the program level with the assistance of the QCC.


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2. Quality Systems Components

2.1. MPCA’s Quality System Description

The QMP documents the MPCA’s strategy for building quality into all its programs. The quality systems include planning, implementing, and assessing the QA and QA operations as they are applied to the MPCA’s environmental data programs.

The MPCA Quality System Plan (Figure 6) encompasses the components and system that ensure quality in the agency’s work. Quality is integral part of each of the components design and management. QMP describes the policies, procedures, and systems governing Agency data collection activities. The MPCA’s QMP is a continuous effort to document review, and manage quality. Quality management is the responsibility of everyone at the MPCA. Staff are responsible for planning, executing, documenting, and reviewing all work performed to ensure that it conforms to the DQOs that were established for the program, project, and services. DQOs are documented in the applicable QAPrP or QAPP. Management and QA staff ensure all facets of quality in the QMP are adhered agency work. The QACs are responsible for writing and or insuring quality-related policies, which are then incorporated by staff into their project Work Plans and QAPPs. Management and staff receive regular training and assistance from QACs within the MPCA. Quality System and QA training is further detailed in section 3.5 Program Specific Training

Documentation is critical to ensure work is done correctly and available for review, as needed. Proper documentation saves resources by enabling staff to review proposed work, minimize errors and omissions, and enables future work to build smoothly upon already completed work. Documentation becomes particularly important as staff are reassigned or move to other positions. New staff must be able to review past work to ensure ongoing project consistency and quality. Examples of QA documents include:

QMP Standard Operating Procedures (SOPs)

QAPrPs Field Manuals

Sampling and Analysis Plans (SAPs) Data Quality Objectives (DQOs)

Work Plans (WPs) Technical Assessments (TAs)

Request for Response Action (RFRA) Data Quality Assessments (DQAs)

These processes and documents help ensure the work planned and performed yield data or results that are of sufficient quality to support the intended use of the data collected or the decision to be made based on the analysis of those data. The various documents or processes serve to give all parties involved written documentation of the work being performed, their responsibilities and requirements, and information as to how quality will be ensured. For specific site work, the documents are legally binding.

Figure 4 Components


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More detailed guidance for quality management can be found in subordinate QAPrP. The MPCA has several implemented QAPrP that include:

Water Monitoring QAPP

Leaking Underground Storage Tanks

Superfund

Underground Storage Tanks

These QAPPS can be found at http://www.pca.state.mn.us/index.php/about-mpca/mpca-overview/agency-strategy/mpca-quality-system.html?menuid=&redirect=1

MPCA quality system tools

The MPCA has a variety of tools available to ensure quality. These tools include guidance documents such as QMPs, QAPPs, DQOs, and SOPs. Training and auditing are also important tools in the agency’s QMP. Not all parts of the Quality System are necessarily applicable to all work sites or programs but, depending on the project DQO, certain parts shown will be applied. MPCA staff, using the project DQO, evaluates these documents to ensure certain requirements are met before work begins. Accordingly, all data are carefully reviewed by project staff and, if necessary, referred to a QAC for additional scrutiny.

2.2. Quality Management Plan Elements

The Quality Management System consists of staff, defined functions, tools, and quality assurance (QA) procedures. Figure 5. MPCA’s Quality System outlines the agency’s QMP framework.

Figure 5. MPCA’s Quality System

A crucial component of MPCA’s quality system is up-front systematic planning. Although projects vary greatly in scope and importance, each should be started in essentially the same way by determining the level of quality required and by planning accordingly. Consistent with MPCA’s graded approach, the level of

http://www.pca.state.mn.us/index.php/about-mpca/mpca-overview/agency-strategy/mpca-quality-system.html?menuid=&redirect=1



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quality required will be determined by evaluating the importance of the activity, available resources, the unique needs of the organization, and the consequences of potential decision errors. These elements explicitly require clear DQOs for each planned Data generation activity, and also require that data assessments be conducted to evaluate the validity of the results.

In addition to the QMP elements (Figure 5. MPCA’s Quality System) specific areas that drive the QMP are as follows;

QA Goals and Policy (identified in MPCA’s QMP)

consistency with EPA and other requirements

ensure that QA measures are value added

defining MPCA’s QA organizational structure

describing MPCA Programs and activities covered by the QA requirements

outlining the roles and responsibilities of those involved with MPCA QA Functions

utilizing QA tools and procedures

establishing a communications process (internal and external)

affording QA training opportunities,

dictating documentation and record keeping requirements,

implementing review and evaluation procedures to ensure continuous improvement, and defining key QA terminology

2.3. Quality System Authorities and Accountability for Managing the Quality System

Quality Assurance Manager

Agency management is committed to ensuring the Quality System is developed and implemented with adequate resources allocated for accomplishment of program goals in the development and execution of all projects and tasks involving environmental information, both in-house and externally. The QA Manager oversees the process ensuring there are not obvious gaps in the quality system across the Agency. The QA Manager receives updates on overall QA systems on a daily basis from the QA Supervisor.

Quality Assurance Coordinator Supervisor

The QA Supervisor is in charge of the day to day oversight of QA planning, review of program/project plans, and training of staff. The QA Supervisor works with the QACs, Sections, and Units across the MPCA to ensure a balance of QA support for the various programs. The QA Supervisor is responsible overall for QA policies, laboratory assistance, and guidance put out by the QA staff throughout MPCA. The QA Supervisor will oversee new efforts such as data quality efforts or emerging issues assigning staff resources to new programs or activities in support of the Agency priorities.

Quality Assurance Coordinators

The QAC’s are responsible for day-to-day quality operations across MPCA programs. This includes reviews of QAPPs, training of staff, interactions with EPA and other agencies involved in different aspects of programmatic and site work, and often answer questions from staff and consultants on environmental chemistries. As part of this, the QAC’s are responsible for the effectiveness of the MPCA’s Quality System. The QAC’s will also ensure the development and implementation of corrective actions in conformance with external and/or internal assessments. QACs work directly with the QA Supervisor when contested issues or


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new and emerging questions arise to ensure consensus when needed from the unit and unity of effort in the QA approach within the MPCA. The QACs are the initial contact for all staff with questions dealing with chemistry and work on a wide variety of projects. When the same question arises often or an issue comes up that will require a decision by management this issue is put on the MPCA QA website in either the frequently asked questions or written into a policy approved by the Agency for use by the public and State. These policies are used to ensure laboratories understand the requirements of MPCA for data being used by the Agency for decision making. The website can be found at http://www.pca.state.mn.us/index.php/about-mpca/mpca-overview/agency-strategy/mpca-quality-system.html?menuid=&missing=0&redirect=1.

Quality Management Plan Approval Authority

The QMP is reviewed by EPA Region 5 QA Managers, GLNPO QA Manager as well as internal MPCA staff to ensure that all elements of the MPCA Quality Systems are adequately addressed. The QMP is to be renewed every five years or sooner if significant changes are made to QMP program elements. Written MPCA QA policies referenced in the QMP may be found on the MPCA website at the QA homepage:

http://www.pca.state.mn.us/index.php/about-mpca/mpca-overview/agency-strategy/mpca-quality-system.html?menuid=&redirect=1.

Quality Assurance Project Plan Approval Authority

The MPCA has designated individuals to review and approve QMPs, QAPPs and other documents, either through formal or informal delegation. If at any time a question of signatory authority arises, the question should be raised to the QA Manager. Normally QAPPs are signed by the project manager and the QAC when needed. Federal sites may require further programmatic and EPA approval, and therefore, appropriate lines of approval are added to the signature page. QAPPs are used whenever environmental data is used for decision making per EPA QA/R5 and G5. Management and QA staff ensures QAPPs are reviewed at the appropriate level within the agency and with EPA when under federal programs such as GLNPO and Superfund. The QAPPs are signed, distributed to individuals working on site, and then stored at MPCA for use during site reviews, audits, or investigations. The QAPP is viewed as the ultimate document governing the work and analytical data produced by the site and is enforced by the MPCA.

2.4. Quality Assurance Project Plans

The QAPP’s are the key documentation step for assuring quality across the agency and with our outside partners. The MPCA requires QAPPs for numerous programs. QAPPs are an important tool for project managers and planners to document the type and quality of data needed for environmental decisions and to use as the blueprint for collecting and assessing those data from environmental programs. The development, review, approval, and implementation of the QAPPs are part of the mandatory agency-wide Quality System that requires all organizations performing work for EPA to develop and operate management processes and structures for ensuring that data or information collected are of the needed and expected quality for their desired use. The QAPP is an integral part of the fundamental principles of quality management that form the foundation of the agency's Quality System. EPA requirements for QAPP’s are outlined in QA/R5. The MPCA QAPP guidance can be found at http://www.pca.state.mn.us/index.php/view-document.html?gid=5477.

MPCA QAPrP examples

The MPCA has a number of Program QAPPs used by staff for work within the program area. These QAPPs set the basic quality standards. Examples of program wide QAPPs are:

Minnesota’s Lake Superior Beach Monitoring and Notification Program





http://www.epa.gov/quality/qs-docs/r5-final.pdf



http://intranet.pca.state.mn.us/forms/grants-qa-project-plan-sample.pdf


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MPCA Water Quality Assurance Program Plan

Underground Storage Tank and Petroleum Remediation Quality Assurance Program Plan

MPCA QAPrP is posted on the Quality Systems webpage.

2.5. Standard Operating Procedures

All sampling and analytical procedures are documented in the SOPs and the MPCA sampling guidance documents. SOPs are written for critical tasks and procedures that merit standardization. The program staff and QAC typically write SOPs based on a project or set of tasks. The QAC gives the SOPs final review and approval. SOPs typically are reviewed and updated every two to three years or based on project needs. The QACs review programs and SOP to insure they are consistent and address current work efforts. Programs manage SOPs and share them with the Environmental Data Quality Unit.

Standard operating procedures requirements

SOPs are developed using the EPA document, Guidance for Preparing Standard Operating Procedures (SOPs), EPA QA/G-6. April 2007, as a guide. All monitoring activities and Data generation procedures are documented in the SOP, which typically includes the following basic elements;

scope and application

methods summary

QA requirements

equipment preparation

calibration procedures

necessary apparatus and materials

safety procedures and precautions

equipment list

standards and reagents

procedures

calculations

references.

The SOP documents processes that are consistently effective and regularly performed, including sampling and analytical procedures, and helps ensure work standardization. A MPCA-prepared or approved QAPP includes SOPs for field sampling and measurement procedures and enables MPCA to ensure work is of known quality that meets data quality objectives. MPCA project manager is responsible for ensuring project staff comply with applicable SOPs.

Examples Minnesota Pollution Control Agency Standard Operating Systems

Lake Water Quality Sampling (link)

Feedlot Global Positioning

Construction Stormwater Standard Guidance Closed Landfill Program (link) Emergency Response (link)

Household Hazardous Waste Programs (link)

Standard Operating System management

Management of SOPs is done at program level. QACs and project staff ensure that SOPs are updated regularly and new ones are put in place when necessary. The MPCA staffs write SOPs for all tasks involving critical tasks that merit standardization. The QAC typically review and advise during SOP development and revision with additional input from knowledgeable staff. The QAC staff give SOPs their final review and approval when involved in the process of building the SOP, at times staff who directly deal with the SOP will write and approve the SOPs through their section leadership. The guidance on the creation of a SOP can be


http://www.pca.state.mn.us/index.php/about-mpca/mpca-overview/agency-strategy/mpca-quality-system.html?menuid=&redirect=1#qapps-quality-assurance-project-plans

http://www.epa.gov/quality/qs-docs/g6-final.pdf



http://intranet.pca.state.mn.us/programs/feedlot/gps-sop-feedlots.pdf



http://intranet.pca.state.mn.us/index.php?option=com_docman&task=doc_view&gid=905

http://www.pca.state.mn.us/index.php/waste/waste-and-cleanup/waste-management/household-hazardous-waste/program-manager-information/standard-operating-procedures-for-hhw-programs.html


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found in the MPCA’s QMP, as well as, in EPA Guidance for Preparing Standard Operating Procedures (SOPs), EPA QA/G-6

Minnesota Pollution Control Agency Contract Laboratory Standard Operating Procedures

The MPCA maintains a file of MPCA contract laboratory SOPs and Quality Assurance Manuals (QAMs), referenced in the QAPP. The SOPs are submitted with QAPPs for site work and often sent in with contract work. The SOPs and QAMs are maintained by the QAC working on the project.

Factsheets

Hundreds of guidance documents and other information have been published by the MPCA regarding its programs. These factsheets and other documents provide guidance as well as help improve quality within the agency’s programs. The agency policies for publishing and managing factsheets can be found in Section 5.7. These documents are catered to the public and outside partners. Some of these types of documents include:

Water-related factsheets Volunteer Surface Water Monitoring Guide Construction Stormwater permitting Underground Storage Tank program documents

2.6. Operational and Strategic Review

The MPCA Executive Team or its designee conducts an internal operational and strategic review on a yearly basis. The internal Operational and Strategic review consists of evaluating the MPCA’s internal management structure to determine whether the agency is implementing policies and achieving goals outlined in the Agency Strategic Plan and thereby measuring whether its quality system is effectively facilitating the implementation and achievement of such policies and goals. The Operational and Strategic review identifies any deficiencies in programs on an annual basis. The findings are discussed with the division and section managers. Supervisors of programs determined to be in need of remedial actions discuss the deficiencies with staff and oversee the implementation of any necessary follow-up actions.

Any required corrective actions identified by an Operational and Strategic review of this scope are directed to the MPCA Commissioner's Office, and the MPCA division directors / management. An operation and strategic review of smaller scope may be conducted at the MPCA manager or supervisor level in program reviews. The findings from a review of this scope are sent to the MPCA division director and managers for follow-up and implementation of corrective actions.

The MPCA Managers prepare presentations as part of the Operational and Strategic Reviews and make a presentation to the Commissioner of the MPCA on measures based on the Agency Strategic Plan. The reports track progress toward meeting the goals and objectives of the strategic plan. Following report review, corrective actions are taken, as needed. Other programs are reviewed in accordance with statutory requirements or deadlines, most of which are related to funding cycles. As noted earlier, the State Legislature or Commissioner's Office may initiate an audit when a significant problem is identified or suspected. The QA unit may conduct a data quality review upon request or specific needs of a project of program.

2.7. Performance Management and Quality

The quality of the MPCA project or site work is monitored through review of the Work Plan or QAPP. Once it is approved, a work order is issued for a site-specific project. As the work proceeds, the MPCA Project

http://www.pca.state.mn.us/index.php/water/water-publications/water-related-fact-sheets-and-publications.html?menuid=&redirect=1

http://www.pca.state.mn.us/index.php/water/water-monitoring-and-reporting/volunteer-water-monitoring/volunteer-surface-water-monitoring-guide.html

http://www.pca.state.mn.us/index.php/water/water-types-and-programs/stormwater/construction-stormwater/construction-stormwater.html?menuid=&redirect=1


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Manager reviews the work being done to ensure the DQOs, QAPP, and Work Plan are being followed. The QAPP also specifies appropriate laboratory analytical procedures. If a MPCA-contracted laboratory is used, it must be certified by an authority as accepted by the MPCA. If a mobile laboratory is used, it must meet specific requirements, which may be found on the MPCA’s QA webpage. Analytical data from mobile laboratories are used only for on-site analytical screening purposes. Major corrective actions require the MPCA Project Manager’s approval. Superfund sites also require EPA Remedial Project Manager approval. After the work is completed, it is documented in the final report. The MPCA Project Manager verifies that the site DQOs have been met, that all site work has been completed, and approves the final report. The QA section of the report is often submitted to the QAC for review and approval.

The MPCA promotes an integrated system of management activities involving planning, implementation, assessment, reporting, and quality improvement to ensure that all processes, items, and services are of the type and quality needed and expected by the stakeholder.

Hiring and maintaining quality staff is a priority of the MPCA. With over 900 staff working across the state in a wide range areas maintaining staff proficiency can be challenging. The MPCA has several staffing general standards as well as training and review requirements.

3. Personal Training and Qualifications

3.1. Qualifications

Personnel that are hired by the MPCA must meet the minimum qualifications based on the duties of the position and the classification. Each classification has minimum qualifications, including academic qualifications, certification, licensures, experience, or a combination of these. The MPCA’s Human Resources Section is responsible for identifying the minimum qualifications and preferred qualifications and conducts position audits to ensure staff is appropriately classified.

Supervisors develop a position description and then work with MPCA Human Resources Section staff work with the hiring supervisors to identify the appropriate classification and specific skills required to meet MPCA staffing needs. Positions are then filled based on contractual language. As an alternative, the MPCA may retain a consultant or contractor to provide the required services, particularly if the need is highly specialized or of limited duration.

3.2. Training

Training is a MPCA priority. Providing access to external and internal training to ensure that MPCA staff retain and enhance their technical competence, perform their jobs more efficiently, and have high morale is considered a necessity. Notwithstanding possible funding limitations, which are always a consideration, the MPCA remains committed to providing staff training opportunities to help them perform at their maximum capability. Responsibility for the MPCA Training Plan is shared with MPCA Leadership, Human Resources Management Team and the Organizational Improvement Unit. Training and development planning is also conducted by supervisors and staff.

The MPCA training includes a wide variety of topics such as continuing education, certification maintenance requirements, regulatory issues, and new technology training. The MPCA also supports the efforts of employees pursuing advanced degrees when the course work is directly related to the employee’s work responsibilities. MPCA tracks training offered and taken by staff on an internal database where management may check training on staff and sign them up for various courses offered by the State to increase training. The software for the database is maintained in the training unit of the OSD division at MPCA.

http://www.pca.state.mn.us/index.php?option=com_k2&view=item&id=524#laboratory-guidance-and-references


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3.3. Training/Trainer Requirements

Training schedules are developed in order to optimize attendance and address specific area of need. Training may consist of seminars or classes, or on-the-job training. If training cannot be met through in-house expertise, it may be accomplished through external organizations. Internal review and approval will be done by management to insure MPCA staff are qualified to act as trainers. Staff training records are managed on a program specific basis and on agency wide bases using agencies online training management tool.

3.4. All Staff Training

Mandatory training for all MPCA staff includes:

New Employee Orientation

Fire Evacuation Plan

Office Emergency Plan

Sexual Harassment Prevention

Data Practices

Computer Security and File Management

Ethics

3.5. Program Specific Training

Program-specific training provided continually at the MPCA. New employees and staff data that directly collect/use or supervise the collection/use of environmental data regularly receive program training. QAPPs and QAPrP specify specific staff training requirements, such as the PCB inspector requirements specified in the Toxic Substances Control Act Polychlorinated Biphenyl Inspection Program Quality Assurance Program Plan (Link). Program specific training requirements are often specified in grants QA/QC training.

MPCA QACs receive and give to staff regular internal and external training on QA issues. Specific QA training topics include:

Laboratory Control and data policies and guidance

DQO requirements

new or emerging analytical technics and associated quality assurance

field QC

flagging of data

Electronic Data Transfer

Specific guidance on these agency QA topics can be found on the MPCA’s Quality System webpage at http://www.pca.state.mn.us/index.php/about-mpca/mpca-overview/agency-strategy/mpca-quality-system.html?menuid=&redirect=1.

The MPCA QACs conduct regular quality training for MPCA staff. Training is conducted based on program request or at opportune events to address staff needs. Staffs enhance their quality systems skills both in-house through QAC-led instruction and externally through classes, seminars, and conferences to learn both fundamental concepts and new procedures. Training may be formal or informal, mandatory or voluntary.






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GLRI QAC received QA training specific to GLRI focused on QA in Great Lakes projects. These training requirements are specified in the grant and can be found at http://epa.gov/greatlakes/qmp/qmtraining.html.

Water quality field work training

New MPCA water programs field staff receive training, participate in professional development activities relevant to their responsibilities, and work assignments. Staff training needs are identified by program and project audits, management reviews, and information received from program and project managers.

Each MPCA position classification is defined by a minimum set of requirements including education, work experience, and certification, if applicable. To help ensure MPCA water programs achieve their strategic plan goals and objectives, staff must meet all position classification requirements. Position classifications are reviewed periodically and redefined as needed to help ensure staff have or receive the necessary skills as program and project objectives change, expand, or are otherwise redefined. Program managers evaluate staff skills and training needs during periodic performance reviews. Project managers evaluate project staff performance and training needs on an ongoing basis. QACs evaluate staff quality proficiency through quality systems reviews and audits.

The MPCA encourages staff to seek training to enhance their skills on an ongoing basis to help ensure that the agency mission is fulfilled. MPCA strives to provide its staff opportunities to participate in local, regional, and national professional conferences and workshops relevant to their job duties and responsibilities. Staff personal and professional development goals are defined and assessed during the staff annual performance review.

New water programs field staff are accompanied in the field by experienced field staff and at times the PM until such time as the new field staff can demonstrate thorough competence in all activities, duties, and responsibilities of the field monitoring position. This includes but is not limited to field sampling, sample handling, sample preservation, sample delivery, sample shipping, field instrument use, instrument standardization, instrument maintenance, instrument repair, recordkeeping, and safety.

All staff training including QA/QC training is documented and becomes part of the staff personnel record. Staff professional development and training activities are constantly evaluated to ensure they continue to meet agency program and project needs.

Biological monitoring training

The MPCA biological monitoring also has an annual training workshop. The workshop is a refresher and train up on fish sampling procedures and aquatic invertebrate collection methods. Giving the high amount of visual assessment used during biological field assessments, this training is critical for consistency among staff.

Other program technical training

Similar training is available for RCRA, Superfund, and Underground and Aboveground Storage Tank Inspectors at the MPCA. Topics include chain of custody procedures, sampling techniques, field documentation, laboratory reports and analytical methods, and program-specific methodologies such as understanding and interpreting chromatograms. This training may be offered section-wide, if an entire section needs training or at a noon-hour seminar, if a limited number of staff and/or consultants working with the MPCA require training. Occasionally, EPA provides training seminars for MPCA staff on topics such as QMPs, QAPPs, or DQOs.

http://epa.gov/greatlakes/qmp/qmtraining.html


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Recurring problems identified by the QAC through self-directed audits often result in program-specific training. The QAC may also provide periodic refresher training on QA procedures to reinforce already-learned QA principles. Upon completion of formal training, staff names and training type are submitted to the Human Resources Department for inclusion in staff personnel records.

3.6. Employee Performance Evaluations

Employee performance evaluations are part of the Employee Performance Management Process. This process is composed of four elements, (1) work planning process, (2) ongoing communication during progress reports, (3) annual performance appraisal, and (4) development planning.

Work planning tools include the position description and the individual’s work plan. Together they form the basis for describing expected performance. The position description defines the overall purpose of the employee’s work and the role the employee plays in the organization. The individual employee work plan, expected to be updated annually, translates the information in the position description into specific objectives and work activities, deliverable work products, and/or outcomes for a defined period of time based on the strategic plan that lists the agency goals, objectives and strategies. Performance assessment starts with routine everyday management. As such, performance management involves frequent, informal, on-the-job contacts between supervisor and staff. The supervisor and employee are also expected to meet periodically to review progress, and produce informal, but written, progress reports when needed and fully written performance reviews on a yearly basis.

Formal performance appraisals are typically done once a year, though they may be conducted more frequently, as needed. In December 2002, an Agency Performance Appraisal Worksheet was adopted, which consists of five sections. Section 1 addresses performance dimensions for which staff are accountable. Dimensions for which all staff are accountable include Commitment to MPCA Goals and Priorities, Customer/Interpersonal Relationships, Responsiveness, Job Knowledge, Communication, Initiative and Decision-Making. Additional dimensions for which managers and supervisors are accountable are Leading, Developing, and Supervising Others, Managing Resources, Integrating, Coordinating, Measuring, and Evaluating. Section 2 is used to assess results of performance objectives specific to the employee’s work plan. A rating scale is used to rate the employee’s performance results for each objective in the individual’s work plan. Section 3 gives an overall performance rating. Section 4 identifies the employee’s development needs. An Employee Development Plan is used to describe development needs in more detail. Section 5 is for employee comments. It is recommended that Performance Appraisal also include a written Employee Self-Assessment. Development planning flows out of the performance appraisal meeting. It may be completed at that time or in a separate meeting. It identifies specific goals for growth and improvement. It includes development needs and/or goals for expanding responsibilities and individual career planning. Individual employee needs and goals should be directly related to the priorities of the agency and based on the agency’s an individual’s work plans.

The Performance Management: Employee Performance Appraisal and Employee Development Plan forms are maintained on the intranet site available to all MPCA staff.

3.7. Training Management

The mandatory training at the MPCA is managed by the Leadership, Human Resources, and Organizational Improvement Unit. Program specific training requirements are managed within each section. The section evaluates the training needs as well as keeps records on training.

The Operations Division includes a training unit that oversees training and tracks this through the Employee development tool that is found as a link on each employee desktop. The database in maintained within the section and used to assign training to employees requiring specific yearly training (such as eight hour safety

http://intranet.pca.state.mn.us/index.php/component/docman/doc_download/1231-Performance-Management:-Employee-Performance-Appraisal?Itemid=56


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refresher training, right to know, fire/tornado safety procedures, etc.). The unit supervisor has access to each employees training record and can assign training as needed to an employee. Employees can sign up for training they need or request on line training as well from this database.

Additionally, units within the MPCA have training sections such as the Certification and Training Unit within the Prevention and Assistance Division. This unit does a number of training events, but of interest to the laboratory community is their work with QA and training for wastewater laboratories which is held multiple times a year throughout the state. The training is conducted by staff who have deep experience in working with wastewater laboratory methods. This training is part of the QA program at MPCA ensuring quality with the partners of the agency throughout the State.

4. Procurement of Items and Services

4.1. Procurement Roles

Each division's administrative staff handles general purchasing, and the agency’s Contracts Unit handles contract requests. A budget is assigned at the beginning of the fiscal year for supplies and expenses (S&E). The S&E budget is used for miscellaneous office supplies, travel, memberships, and training. This budget is tracked by the Section Managers and Office Administrators of the divisions and reported to the Division Director.

Adherence to contract provisions in all areas, including QA, is generally the responsibility of the Project Manager (PM) in charge of a specific site, facility, or program. They ensure all necessary documentation of the audits or reviews are in the site files and technical staff reviews these findings to ensure that the work is complete. For example, if a PM requests an audit, a sampling expert and possibly a QAC would meet with the contractor and monitor the contractor’s procedures. An audit summary would be prepared for the PM with recommendations for corrective actions. The documentation from the audit and corrective action would be filed by the PM on the site, but the QAC and the sampling expert would also maintain copies. Repeated failure to adhere to the terms and conditions of the contract may result in the MPCA withholding payment and, if necessary, terminating the contract.

Although MPCA staff are primarily responsible for the day-to-day evaluation of contractor performance, supervisors also monitor performance by tracking work progress at sites and facilities assigned to their staff.

4.2. Procurement Rules

The Minnesota Department of Administration has purchasing requirements that the MPCA must follow. These guidelines ensure that state agencies procure goods and deliver services efficiently and in accordance with state law. The Department of Administration also establishes various commodity contracts with supplying vendors, which permit all agencies to buy goods in a legal, efficient, cost-effective manner without concern for local purchase authority. If an item is not available through a contract, then an open competitive bid process is followed. Contracts are awarded to the lowest responsible bidder meeting specifications and other conditions specified in the call for bids.

Contracts

The MPCA contracts with numerous vendors, laboratories, and technical firms for a variety of products, sampling services, and analytical needs. MPCA policy requires that laboratories performing analyses in support of MPCA programs be certified by the Minnesota Department of Health (MDH), registered with the MPCA or another program as approved by the State, as appropriate. The firms are retained by contract


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through a process directed by the Department of Administration. The contracting process begins with the MPCA Contract Specialist organizing a team of staff members representing programs that use the contract services. The QAC staff assists in Request for proposal (RFP) development by ensuring the QA/QC requirements are included in RFP’s.

Once the team development process has been completed, the task of developing a RFP begins. This process sets forth the MPCA requirements and the minimum technical qualifications the proposer must have to be considered for the contract.

The Department of Administration reviews the draft RFP to ensure state requirements are met and attaches the State’s special terms and conditions. Upon approval, the RFP is sent to known interested parties and is published in the State Register. A question-and-answer period or pre-proposal meeting is then held during which time MPCA staff clarify the RFP requirements and answer questions from prospective proposers and other interested parties.

Following the question-and-answer period, all questions and answers are provided in writing to all interested parties. The Department of Administration sets a deadline by which all proposals must be submitted. The RFP team reviews the proposals, scores them in accordance with preset criteria, and selects the winning proposal(s). The Department of Administration then notifies the successful contractor(s) and the contracts are negotiated and executed.

The MPCA grant/contract managers continuously monitor contractor performance through work plans, project schedules, and task tracking. Oversight of work plans insure quality and completion. Each MPCA work plan includes the following elements:

1. Project Summary 2. Statement of Problems and Existing Conditions 3. Project Goal, Objectives, Tasks and Sub-tasks 4. Measures and Outcomes 5. Gantt Chart (schedule) 6. Project Budget

Laboratory contracts

For contracted laboratory services, the QAC may conduct an audit either before execution of the contract or at any time during the term of the contract to determine if the laboratory meets the QA requirements for the contracted work. Currently all laboratories directly contracted with the MPCA are audited by the QACs. Laboratories are provided the criteria for the audit. If the laboratory fails the audit, it is given a specified period of time to remedy the identified deficiencies and is then re-audited. A second failed audit may result in the laboratory either being disqualified from further contractual consideration or, if the contract has already been awarded to the laboratory, termination of the contract.

QACs may monitor compliance with the terms and conditions of laboratory contracts regarding data quality. MPCA staff review data reports and invoices while the QAC may submit double-blind analytical check standards and conducting data audits. All contractors are required to submit analytical results from Proficiency Testing samples to the State. All contractors are required to follow policy and guidance documents that are posted on agency webpage. All contractors subcontracting analytical work to a laboratory must ensure that the cover sheet of all data reports submitted to the MPCA include the laboratory certification number.


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4.3. Quality Assurance Requirements -Agreements

The MPCA has many agreements and contract with other agencies and organizations. Many of these agreements have specific QA requirements. MPCA program staff and QAC’s work to maintain QA requirements (such as QAPPs) ensuring terms of agreements are met. An example of a QA agreement is the EPA –assistance agreements requirements under grants.

4.4. When Is A Quality Assurance Project Plan Required

The U. S. Environmental Protection Agency (EPA) requires QAPPs any time data is being collected for use in making a decision. This normally would require a QAPP for all projects, but the MPCA does use Sampling and Analysis Plans (SAP) in certain circumstances (e.g. Voluntary Investigation and Cleanup projects, small Resource Conservation Recovery Act sites, Leaking Underground Storage Tanks (LUST) site reports, etc.). Project Managers identify a laboratory (or multiple labs if required), have the laboratory QA Manual and appropriate SOPs for inclusion or reference for the completion of the QAPP or SAP if used. The consultant firm/author must identify the timeline for the work to be performed. If one of the major parties is changed (e.g. a new laboratory or consultant is hired) then an amendment to the QAPP must be written or after five years a new QAPP produced regardless. The EPA and MPCA consider a QAPP to be the final word when a disagreement arises on the site dealing with anything covered by the document. Therefore, it is imperative that the document be complete and agreed to by all parties. Additionally, all parties must have a copy of the QAPP available for reference prior to and when the work is being performed. More information on MPCA QAPP requirements can be found in the MPCA’s Quality Assurance Project Plan Guidance QAPP Fact sheet on the web at http://www.pca.state.mn.us/index.php/view-document.html?gid=5477.

5. Document Control and Records

5.1. Record Storage

Records management at the MPCA is a complex operation. Records reside in numerous places for a variety of reasons. Some records reside in network drives for collaborative purposes, resource repositories, and for linking to external websites. Other records are paper and reside in formal file systems. Records may also reside in databases and e-mail. However, all records generated or received in the course of business, regardless of format, origin or storage location are considered State of Minnesota assets and are governed by the Minnesota Government Data Practices Act (Minn. Stat. § 13), the Official Records Act (Minn. Stat. § 15.17), and the Records Management Act (Minn. Stat. 138.17).

Specifically, the MPCA uses an electronic document management application to manage electronic documents called OnBase. OnBase is integrated with the MPCA’s legacy databases and also several key state databases. This integration forces consistent metadata values be applied to records and supports data. The same security standards and backup practices mentioned below also apply to OnBase. In order to be compliant with the MGDPA, OnBase is able to apply security at the document level.

The OnBase system is located on the MPCA network server. The MPCA’s Network servers are protected using a variety security tools including firewalls, malware and antivirus applications. The security of the MPCA’s computer system meets or exceeds the State of Minnesota’s security requirements set by the Minnesota Office of Information Technology (MINIT) Services and the Minnesota Department of Administration. The computer system is regularly backed up according to a schedule determined by the Information Technology Office.




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Active paper records are stored on-site at the MPCA in centrally-located file areas within rotating file devices called Lektrievers and also in conventional lateral and vertical cabinets. Inactive paper records are stored off-site in a secured state contracted storage facility.

5.2. Record Control

Files are preserved pursuant to the terms prescribed in the MPCA record retention schedule. The number of years that files are kept at the agency and then archived varies with each retention schedule. When archiving documents, the file managers:

Advise division staff as to which documents should be designated for off-site storage.

Prepare documents according to established requirements.

Create an index of documents within each box being sent to archival storage.

Verify the accuracy of each index contained in the boxes being sent to archival storage.

Complete the required paperwork and secure the necessary approval for transferring boxes to archival storage.

Create new district retention schedules and revise existing ones as the need arises.

Monitor the retrieval of documents from archival storage.

The majority of agency files sent to archival storage are in paper form. Some documents are reproduced onto microfiche, which is kept on-site at the agency as well as in archival storage. The retention period for electronic documents is the same as paper documents. When an electronic record reaches the end of its lifecycle, it will be purged from the system.

Files can be easily retrieved by file management staff when needed. Records are maintained as to which files are recalled.

Records Management Officer

Under the agency’s Operation Section in the Records Management Unit is the MPCA’s Record Management officer. The position is located in the St. Paul office and has oversight of the agencies filing systems and all of the file manager staff in the MPCA. This position reports to the Assistant Chief Financial Officer of the MPCA. The Records Management Officer is also responsible for identification and management of vital records.

File Managers

The agency employs staff to maintain these filing systems. These staff are assigned to manage specific record collections. Their working title is “file manager”. The names and contact numbers of the file management staff are listed on the Records Management Webpage on the MPCA intranet. This information is also in the MPCA’s “Who to Contact/IRI” directory. The file managers are charged with:

Establishing and complying with filing policies and procedures for the agency.

Developing file and taxonomy structures as needed for programs.

Filing all paper documents according to policy.

Reorganizing out-of-order files according to policy

Shifting documents to redistribute space within the filing system as the need arises.

Assisting staff members and external customers with locating documents within the file systems.

Providing training to division staff members specific to the filing needs of their respective programs.

Adhering to the MPCA Retention Schedule.

The agency’s Records Management Policy and the Retention Schedule can be found on the MPCA Intranet.

The agency file managers meet on a regular basis to:


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Ensure that file management policies, procedures and practices are consistent throughout the agency.

Share information and discussing file management issues that affect the agency.

Ensure agency compliance with Minnesota rules and statues regarding data practices issues.

Develop ways to provide excellent service to internal and external customers.

Make recommendations to management regarding file management issues such as daily operations and future improvements.

Review the strategy for the agency-wide document management policy.

Administrative Records are also created and maintained, as needed. The file managers:

Compile administrative records files for new and existing Superfund remediation sites in compliance with the Superfund Memorandum of Agreement (SMOA).

Train staff in the administrative record requirements described in the SMOA.

Arrange for the copying and distribution of administrative record documents to appropriate information repositories throughout the state, when needed.

Create an index of documents included in each administrative record.

Respond to requests from external customers seeking information in administrative records.

Staff Responsibility

As specified in Minnesota Statute, Ch. 15.17, staff are required to make and preserve all records necessary to a full and accurate knowledge of their activities. All staff attend training on record generation, preservation and data practices requirements. On-line training modules are also available for refresher training.

File maintenance is the responsibility of all staff. All staff members have access to agency files during normal business hours. A check-out system using sign-out cards is used to keep track of all paper files checked out of the file rooms by staff. External customers are required to schedule an appointment to review agency files. External customers are not allowed to borrow agency documents, but may request copies. All documents remain in agency possession at all times. Most files are unlocked during non-business hours. Confidential documents are stored in secured areas within each file room.

Staff members are also responsible for importing electronic files into OnBase, filing the documents in their work areas or submitting filing to the file management staff according to their program’s practice. Staff members determine metadata information as to how various documents should be filed within the recordkeeping system. Staff members refer all requests for information, including Freedom of Information Act letters, Minnesota Data Practices Act letters, and file review requests to the appropriate file manager.

5.3. External File Review

Files may be reviewed by external customers. The file staff members:

Ensure that external customers are scheduled for file reviews according to agency policy.

Locate all division files that the external customers request to review.

Prior to file review ensure that requested files are reviewed by division staff for confidential, security, and whistleblower-type information when appropriate and in accordance with Minnesota statutes.

Greet external customers, explain the agency’s file review and photocopy policies, and answer questions about division programs.


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Serve as liaisons between external customers and division staff assigned to remediation sites that are being reviewed, by consulting with appropriate division staff when questions are raised during the file review.

Maintain a record of appropriate signatures and billing information from external customers as required by agency policy.

Comply with document photocopy requests in accordance with agency policy.

Verify the authenticity of agency-owned files by authorizing a notarized affidavit when records are subpoenaed by a state or federal court.

File managers respond to written and oral requests for information through the Freedom of Information Act and the Minnesota Data Practices Act using the appropriate division files. They:

Contact external customers to answer questions concerning the site file, explain agency file review and photocopy policies, and act as liaisons between appropriate staff and external customers to answer complex questions raised in the request.

Conduct research on additional file information as needed based on conversations with the external customers.

Files that require documentation for litigation purposes are number-stamped by the file managers. These file managers:

Gather all site documents from the central file, archival storage, and staff work areas.

Consult with Office of the Attorney General staff to assign categories and numbers to the documents within the site file.

Reorganize the file in accordance with the categories established in consultation with the Office of the Attorney General staff stamp the documents with the assigned numbers.

Compile a list of all documents in the file with their corresponding numbers and distribute this list to the Office of the Attorney General, the staff members assigned to the site, and external customers requesting a copy of the list number-stamp any new documents added to the site file, update the list, and distribute it accordingly.

When appropriate, number-stamping may be done by a vendor outside the agency.

5.4. Technical Guidance Documents and Factsheets

When a need for a technical document or factsheet is identified, an author team of staff from the relevant program defines the project, completes subject research, and creates a draft version. The draft is then routed for review and comment to other staff, management, and QACs who are knowledgeable about the subject matter. Consultants, laboratory representatives, and EPA staff may also review and comment on the document, if applicable. The author team reviews the comments and typically revises the draft based upon comments received. A final draft is submitted to agency management and EPA staff, if necessary, for approval. Documents produced vary from a one-page factsheet on how to properly dispose of used motor oil to an agency-wide Quality Management Plan, which may comprise a hundred pages or more.

The MPCA staff develop many technical guidance documents and factsheets to assist consultants, the general public, and other interested parties. The MPCA seeks to disseminate this information as broadly as possible. Technical guidance documents and factsheets for all the environmental programs may be found at the MPCA web site: http://www.pca.state.mn.us/publications.html. In addition, a factsheet entitled, Creating Factsheets and Other Documents, to assist staff in creating new technical guidance documents and factsheets, may be found on the MPCA web site at http://intranet.pca.state.mn.us/forms/i-admin1-00.doc. Technical guidance documents and factsheets are updated regularly to provide end users with the most current information. Older versions of these documents and those concerning obsolete topics are taken out

http://www.pca.state.mn.us/publications.html

http://intranet.pca.state.mn.us/forms/i-admin1-00.doc


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of circulation. To simplify the document development and updating procedure, a streamlined, systematic process has been implemented at the MPCA. This process is as follows:

5.5. Quality Assurance documents

QA/QC documents such as training records, QAPPs, QAPrPs, and SOPs are kept using the MPCA’s document control and storage system. Typically documents are kept with the project files by the project managers and when appropriate, the QAC staff. The QA manuals are updated regularly by the laboratories, MPCA QA staff, and consultants. The QA documents are periodically reviewed by the author team and QACs. Recommendation for updates and changes are done as needed. Only one copy of QA/QC documents used by multiple sites or programs, is kept on file. This enables consultants to submit SOPs with Work Plans or QAPPs, and merely reference the QA manual without repeatedly resubmitting it.

5.6. Planning for a New Document

The MPCA maintains an inventory of documents placed on the web, forms, factsheets and technical guidance documents for control purposes. Any document being placed on the web is required to go through a rigorous review and approval process to ensure content, form and relevance standards are applied. To aid the document author(s) in determining if it should be placed in the organizational scheme when completed, a factsheet organization chart has been developed. Program staff work closely to ensure that document placement within this scheme is appropriate. Most documents are available on the agency web site to facilitate ease of access by consultants, the general public, and other interested parties.

5.7. Creating a Factsheet

An agency factsheet template has been developed and is used when creating new documents and updating existing ones. The template may be accessed on the MPCA website at http://intranet.pca.state.mn.us/forms/index.html#factsheet. Standardized headline, subhead, and body text styles are used. To maximize the end users success when searching for documents on the web, a specific convention for use of Uniform Resource Locators (URLs) is mandatory. When creating a document for placement on the web, it is imperative that the document summary also follow a specific convention. This enables web search engines to provide a useable search result for the document.

5.8. Special Considerations for Legislative Factsheets

Legislative factsheets are saved on the X drive in the MPCA internal folder system. Agency policy is to retain legislative factsheets created in the current year plus those from the last two calendar years.

6. Information Management

Data management serves a critical function in both preserving information and making that information available. Data management necessarily encompasses a variety of activities related to planning environmental monitoring, collecting samples from different media, laboratory and in-situ analysis of samples, organizing and storing resulting data, analyzing and interpreting data, disseminating data, and communicating the monitoring results and knowledge gained. The way MPCA manages data has evolved substantially in the past decade primarily due to Internet availability (e.g., opportunities in electronic government), increased emphasis on enterprise architecture, and the need for better security of environmental data. Also, MPCA strives to comply with all EPA standards and regulations, as appropriate, pertaining to hardware, software, database system development, and data reporting. This section

http://intranet.pca.state.mn.us/forms/index.html#factsheet


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summarizes the department’s information management practices and related information technology topics. Additional aspects of project management, such as planning, data gathering, and evaluation by MPCA Programs, are addressed in the QAPrPs or other project planning documents as appropriate.

The Information Systems Office (ISO) manages and maintains the hardware and software required for MPCA information management. MPCA staff must comply with ISO-established hardware and software use protocols that are available on an internal, nonpublic web page. ISO staff informs agency staff when protocols are revised or updated.

6.1. Information System Integration

Computer hardware and software standards

The MPCA Information Technology requirements are directed by Minnesota Information Technology (MN.IT). MN.IT encompasses all IT professionals within the State systems as of 2012. The MN.IT office publishes standards and policies the effect all state agencies which can be found at http://mn.gov/oet/policies-and-standards/.

6.2. Data Quality and Data Integrity

The MPCA uses numerous work information management systems for efficiency and quality management. Data integrity and data quality are related in the fact that both are needed to ensure that the data are sufficient for their intended use. For the purpose of this document data quality relates to the process used to collect, analyze, verify, and validate environmental results. Data integrity relates to the input, storage, maintenance, and retrieval of those results.

Data quality

Before environmental data are entered into any database, and released for production, producers of the data shall use a standard QA review/validation/verification procedure to verify that they meet the requirements of their intended use. QAPrPs describe the level of QA/QC necessary for their programs and should include references to how data quality is determined with regards to precision, accuracy, representativeness, comparability, completeness and sensitivity. Regardless of the data entry method, manual entry or electronic file transfer, project managers verify that the data meet the above criteria prior to input into the database in a final format for use by staff. Questionable data may be entered and maintained in a database if they are appropriately documented, qualified, or separated out from use by the public.

Data integrity

The data integrity process begins once the data are ready for input into the databases. Data Integrity addresses the vulnerability of the system to unauthorized access, data manipulation, theft, and environmental damage. Security of the data systems at the MPCA through password protection and limited rights given to users of databases is used to ensure data integrity. Further, data is screened for outliers or anomalies within the database to verify integrity remains accurate across the databases at MPCA.

6.3. MPCA’s Green Data Program

The MPCA’s Green Data Program is a planned component of the blanket Quality Management Plan that covers all aspect of the agency. The planned program will cover all MPCA programs and insure quality data used for decision making and gathered by the MPCA meets the needs of the planned data objectives. Figure

http://mn.gov/oet/policies-and-standards/


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6. MPCA Green Data Program shows the components of the Green Data Program as being currently planned.

Across the agency, we have a broad range of data types including ambient, regulatory, continuous, and calculated. The data comes for numerous matrices including air, water, soil, and animal tissue. The task of insuring high quality data considering: program diversity, database complexity and the amount of data make insuring the implementation of the Green Data Program a challenge. The Green Data program will work with MPCA programs in a systematic tiered approach addressing the quality of data in the MPCA data systems looking at both the data coming into the Agency as well as data currently within MPCA databases.

Figure 6. MPCA Green Data Program

The Environmental Data Quality (EDQ) Unit is launched Pilot Data Quality Project called Green Data 2012. The green data project will begin with the MPCA’s surface water database EQuIS. The Green Data program will addresses the data quality components shown in Figure 6. MPCA Green Data Program by the following processes:

Data Systems Have Quality Guidelines

Input Screening

Data Auditing

Determine Data Quality Measure

Data Quality Reporting

The EDQ Unit will work with a team of staff from across the Agency to define the green data process. The purpose is to ensure data at the MPCA meets minimal quality requirements for the data’s defined use in the programs. The EDQ unit will work with program staff and database managers ensuring data entered into Agency databases meets the requirements of the program QAPP and requirements of the method by which the data was collected and analyzed. Data that exists in databases are planned to be reviewed for range to identify outliers, ensure data is of a known source, a review of metadata, and quality assurance information associated with the data.

New databases are being brought on line or expanded at MPCA (e.g. EQuIS and HYDSTRA) which will be informed by the Green Data Program. The goal is to produce business rules which cover receipt of data, data review, documentation, and separation of data of questionable quality from usable data. Quality Assurance Coordinators are becoming involved with teams in specifying requirements for emerging databases.

6.4. Databases

Site Remediation Database

The MPCA’s Site Remediation Database tracks project information concerning Minnesota’s Superfund, Voluntary Investigation and Cleanup (VIC), and RCRA remediation sites. It is also used for producing accurate and timely reports on program performance and site status.

Completeness

Accuracy

Integration

Timeliness

Consistence

Valid


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It is a Microsoft Access database and consists of user-friendly graphical screens that are used to view and enter project information. It contains a variety of project information as described below.

EQuIS/WQ database

Since 1972 the home for all of the MPCA’s ambient surface water quality monitoring data was the STORET database. The EPA created and distributed STORET, but stopped supporting the software as of September, 2009. The MPCA decided to take this opportunity to find new database software that would better suit their needs.

After an exhaustive collection of user requirements, MPCA concluded the EQuIS database would be the best fit to replace STORET as the agency’s water quality monitoring database. In early 2009, the agency purchased EQuIS (www.EarthSoft.com) and since then staff have been setting up the database, migrating the STORET data, and entering new data. The database currently contains the surface water data for the agency, part of the groundwater ambient program data, and will soon start receiving remediation data. Further work on field sampling and electronic data transfer of field data is currently underway as well as laboratory electronic data deliverables.

Current Status and Process

The most up-to-date information is kept on the MPCA Surface Water Data Submittal, Review and Reports website. An annual review of data submitted for the surface water program is done on a yearly basis at MPCA to verify data from the year. The following timeline is used for this process;

June 1: Submit project, station, and lab metadata

November 1: Submit project lab and field data

December 1: Begin final data review

January 2, following year: Complete final data review

February 1, following year: Data ready for assessments

Data providers are required to submit three types of metadata forms—Project, Location, and Lab Establishment—available on the new Surface Water Data Submittal webpage. Data providers are required to submit data in data template if a laboratory other than the MDH laboratory was used. Data generated from MDH are sent directly to the MPCA where staff matches the lab data with the corresponding field data before both are entered into the EQuIS database. New software being implemented in the spring of 2013 will automatically match the field and laboratory data for samples taken in the ambient groundwater and surface water programs. This software is intended to eventually be used by the majority of water samplers submitting data to the MPCA.

While the transition to the new EQuIS data system is complete, a number of needed improvements in process and software tool development have been identified by the EQuIS workgroup. These improvements affect staff efficiency and QA in data handling both in storage and use after retrieval. MPCA staff will work on these improvements in priority order as staff resources permit. Here are some examples of processes likely to change in the foreseeable future:

New EQuIS data submittal formats will be posted and implemented once an Electronic Data Deliverable (EDD) format is completed by MPCA and the contract laboratories. Currently the EDD is being worked on but is anticipated to begin being used in the spring of 2013.

EQuIS will be expanded to add groundwater from remediation sites and contaminated sediment. The system could one day take data from the waste water program.

http://www.earthsoft.com/

http://www.pca.state.mn.us/index.php/water/water-monitoring-and-reporting/equis/equis-program-and-surface-water-data.html


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Delta database

Delta is the MPCA's agency-wide permitting, compliance, and enforcement information management system. It was designed in four similar segments grouped by program: Air Quality, Water Quality, Hazardous Waste, and Solid Waste. It is designed to support the information management and processing needs of the programs. In addition, there is a shared central Core database that contains basic data for all the project sites such as names, addresses, contacts, and locations. The Core database has about 120 tables and each program database has from 120 -210 tables. Each is a client/server system that runs on approximately 750 client work stations and multiple database servers.

Each of the program databases supports a number of key DELTA functions:

Permitting/Licensing (permit or license requirements are created and stored for future tracking).

Compliance/Inspection (inspection data are entered to track compliance with regulatory requirements).

Enforcement (enforcement actions and related corrective actions are entered and tracked).

Operator Certification (enables tracking of operator certification and employment history).

Mailing Lists (enables the creation of mailing lists using Core data to satisfy many business needs).

In general, relationships within each database segment are based on a program interest. A Program Interest is any activity in which a program has an interest. Functionally, it is typically a permitted or licensed facility. A project site may have one or many program interests associated with it. For example, a project site may have a water treatment system (Water Quality program interest), an industrial landfill (Solid Waste Program Interest) and a smoke stack (Air Quality program interest). With the Site and program interest structure, MPCA staff may determine if a project site has such multi-media activities. The Core stores the high-level facility data while each of the programmatic databases provides the opportunity to access detailed information concerning the facility and its activities.

Each of the programmatic databases has a manager champion and a data steward team to ensure that all issues defined by database users are reviewed, evaluated, prioritized, completed, and tested. These teams are designed to give the Information Systems staff direction on what database modifications are required. Issues can be bug fixes, enhancements to the current system, and the development of report generation functions that enable staff to extract data stored in the various databases. The databases change as the business needs of the programs change and as the business staff better understands how the stored data can help them do their work more efficiently and effectively.

Closed landfill environmental database Management System (EDMS) database

The MPCA Closed Landfill Program (CLP) EDMS Database tracks 107 facilities in 52 Minnesota counties. The EDMS database has grown to approximately 2.6 million records since 2001. Historical data from 1990- 2001 is also stored in the database. It also contains performance data for remediation systems at closed landfills. Media represented include landfill gas, groundwater, surface water, leachate, gas condensate, and treated groundwater. The data is accessed through a Graphical User Interface (GUI) using Microsoft Access 2002 and data storage is in Oracle8i. Technical staff in the CLP use the database to determine compliance with regulatory requirements in surface water, groundwater, and landfill gas to generate monitoring work plans and to write annual reports of activities at the site over the past year.

Data is collected for the various media by private contractors to the MPCA. They submit the data to the MPCA in electronic comma delimited format. MPCA technical staff validate the data through an internal web interface and if it passes validation, it is imported from the web interface directly into Oracle for storage.


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The Main Menu in the GUI enables the user to access facility information, review an on-line EDMS Data Dictionary, and manage lists. List management includes the Master Parameter List, Parameter Lists, and Groundwater/Surface Water Standards Lists. The Master Parameter List contains all the parameters analyzed in the program, including laboratory and field parameters and uses Chemical Abstract Society (CAS) numbers for uniqueness and if none exists, the National Environmental Methods Index (NEMI) numbers are used. If neither exists, the number is created using a convention developed in IGWIS. The Parameter Lists are database-wide lists used in queries and customized reports and graphs. List ‘8260’ contains all the volatile organic compounds by GC/MS, SW-846 Methods, and MDH billing code 468. Groundwater/Surface Water Standards Lists contain performance standards for both ground and surface water. The HRL/HBV/MCL List contains all health risk limits (HRL), health based values (HBV), and maximum contaminant list (MCL) parameters and is used to determine compliance.

The Facility Main Menu allows the user to manage facility information, sample stations, sample station lists, work plans, and sampling events. This menu also allows the user to browse data by event, station, or parameter. Reports are accessed from this menu. Sample station lists enable the user to customize lists of stations in different aquifers or at similar levels within an aquifer to filter data associated with the list. Work plans such as facility sampling can be generated by the EDMS for transmittal to a private contractor specifying stations and parameters to be sampled. Each work plan is associated with a sampling event and is a key element of data validation when it is imported into the system through the web interface.

The Reports Main Menu enables the technical user to generate the following reports: DNR Annual Water Use (Water Appropriation Report), MCES Special Discharge Report, Total Volatile Organic Compounds Report, Total Volatile Organic Compound Mass Report, Exceedance Report (groundwater or surface water compliance determination), Vertical Gradient Report, Graphing Reports (either with one parameter and multiple stations or one station and multiple parameters), Sampling Event Report (report of analytical data), and the Dakota County Report (report to Dakota County in its database format).

Data can also be retrieved from the EDMS through user-specific queries developed in Access2002. User-specific queries have been generated for staff in other MPCA programs and for outside consultants. In addition, each station in the EDMS has location coordinates in UTM NAD 83 Zone 15 so that the station can be spatially represented in a GIS environment

Air quality databases

LIMS

The Air Monitoring Unit uses a server-based Air Laboratory Information Management Systems (LIMS) database system to manage the high volume of data generated from all aspects of air monitoring, including data validation, storage, and retrieval.

This system is used for inventory tracking and instrument calibration and quality assurance, both in the field and in the laboratory. In addition, LIMS maintains all information regarding monitoring sites and support equipment.

AQS

The Air Quality System (AQS) is EPA's repository for ambient air quality data. Within 90 days of the end of each quarter, MPCA reports all ambient air monitoring data directly to AQS via the internet. Invalidated data are reported with assigned null data codes. The MPCA also reports quarterly precision, bias, and accuracy data consistent with the data reporting requirements specified for air quality data as set forth in 40 CFR § 58.35(c)


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Hydstra

Surface water hydrology time series and supporting data are currently stored in the Hydstra system. Hydstra is a suite of applications and database backend from the Kister’s Company. The implementation of Hydstra at MPCA is a joint effort with DNR. The database and applications are housed on a metaframe server accessible to both agencies. Access to the server is controlled by Citrix/Metaframe accounts. Access to the Hydstra application is controlled by user rights built into Hydstra. Read-only access to Hydstra data is provided internally to MPCA staff through a Microsoft Access front-end and through a web application housed on the Hydstra server.

Hydstra data is closely scrutinized through a two level peer initiated audit process. Data is worked up in the system by the assigned Station Manager and Data Manager if assigned, according to written policy and procedure manuals. Raw data is preserved and corrected in a new data signal. Some types of corrected data are used to create a new derived data signal (e.g. Flow from stage). Some data signals are aggregated to new time-steps (e.g. Unit Value discharge aggregated to Daily Value discharge). Comments are used throughout the data workup and all data signals are kept separate so any adjustments, derivations, or aggregations can be traced back to the raw data signal. An automated electronic audit is refreshed every morning to show the current state of data for all stations in Hydstra for the year. Once data meet internal criteria for review according to this electronic audit, a manual audit is performed by a peer panel with the Station Manager being present to answer questions and receive feedback. This manual audit review is repeated as necessary until the data is approved by the panel. At that time data are marked in the system as “Published” and is locked from further changes.

Environmental Data Access (EDA)

The MPCA has developed a database system to provide access to environmental data over the Internet. This system is known as the Environmental Data Access (EDA) system and provides access to surface water quality data. The development team is expanding this system to provide access to air quality and groundwater data.

The EDA system relies on EQuIS for the storage and retrieval of surface water quality data for lakes and streams. Therefore, all surface water quality data must adhere to the protocols required for data in EQuIS. The system presents up to fourteen standard water quality parameters on the webpage for both lake and stream stations for each calendar year with measurements. Additionally, a user can download the displayed water quality data and additional parameters, if available. Users also have access to biological data, which are collected and maintained by MPCA in a separate database that includes measurements, such as the estimated number of fish and the fish species present in a stream segment. Additionally, surface water discharge data from MPCA-permitted facilities are also available. Lastly, the system uses a map viewer to display graphically the results of 303(d) and 305(b) surface water body assessments conducted by the MPCA.

6.5. Information Strategy

The MPCA is developing an information management strategy that will include both Information Systems and Communications. This approach integrates many diverse elements and saves staff time and avoids duplication of effort. The goal is to develop a comprehensive information strategy that will enable agency management to accomplish the MPCA’s mission through the generation, use, sharing, and evaluation of information.

This strategy will:


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Establish management responsibility for MPCA data and information by the agency management team.

Show how the generation, use, and evaluation of information will help the MPCA achieve its mission.

Guide management decisions concerning communications and information systems priorities and resource allocations.

Guide decisions concerning the roles of staff and the Leadership Team in implementing the strategies.

Describe the MPCA’s current information system and leveraging opportunities.

Enable lower level strategies for communication and information systems to be developed.

The vision for the information strategy is:

For citizens to have accurate and timely answers to their questions about environmental quality thereby enhancing their awareness and understanding of environmental issues in their community and world.

To have a well-informed public that recognizes the value of environmental protection and to have well-informed stakeholders and legislators that recognize the role the MPCA plays in providing that value.

To motivate people to assess their behavior and make informed decisions based on what they learn from information concerning the environmental effects of those decisions.

To help communities, industries, and organizations pursue information-based communication, environmental problem-solving, and self-sufficiency.

For MPCA staff to have access to data and information they need to effectively perform their jobs.

To enable MPCA managers to lead the agency and use its resources wisely.

6.6. Data Quality Audits

The MPCA technical staff perform quality audits on all data generated for use in regulatory and monitoring programs. The program project manager has ultimate responsibility for data review. The QACs and the programs they support are listed in Table 3. Data submitted to the QACs for review are scrutinized for completeness to ensure that QA data meet DQO requirements, and to ensure that all data technical requirements are met. This process will vary depending upon the DQO requirements. The data are always audited against established criteria, accepted methods, the National Functional Guidelines (NFG), or predetermined specifications. The laboratory may also be audited and a report written that discusses the audit. Data may be flagged to inform the data user of any data limitations. Normally, MPCA uses flags assigned by the Contract Lab program although a new list of flags has been developed for use with EQuIS which may supersede the old flagging system. When major problems are found, a meeting may be held to discuss corrective actions with all involved parties and come to resolution on issues before further work is done.


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7. Quality Planning In order to accomplish its mission, the MPCA must effectively plan and implement environmental information collection activities. Collecting environmental data of appropriate quality for its intended use is a priority and is a product of systematic planning. In accordance with the MPCA’s graded approach the level of detail in planning and documenting the planning process should be commensurate with the importance and intended use of the work, available resources, and unique needs of the organization.

7.1. Minnesota Pollution Control Agency Strategic Plan

The MPCA insures accountability for the environmental work we are asked to do with periodic reviews. Selected measures show progress on Agency Strategic Plan goals and objectives and on the operational outputs that support the Agency Strategic Plan. It is the 'Check' and 'Adapt' pieces to the Plan, Do, Check, and Adapt Cycle. Every six months each policy forum (Air, Water, Land, and Excellence) reports on their progress. Each spring they report annual progress on Operational measures and each fall they report progress on Strategic measures. Links to the left show previous performance reviews, the review process for each Division and a detailed metrics table. Please see the MPCA Strategic Plan.

7.2. The Minnesota Pollution Control Agency’s Strategic Plan: High Level Planning

Figure 7. Relationships and planning horizons

Historically, the MPCA reflected its work, at a high level, in the long term vision and goals of the MPCA’s Strategic Plan. The Strategic Plan, last updated in 2008 (but currently being updated with a final plan being published early in 2013), sets strategic visions for the agency’s environmental and operational work:

Clean Water Supports Aquatic Ecosystems, Healthy Communities and a Strong Economy

Clean and Clear Air Supports healthy Communities and a Strong Economy

Minnesotans and MPCA Take Action to Protect our Land, Water, and Air

The MPCA will Demonstrate Excellence in Operations

Based on the visions, the MPCA has developed long-term goals, objectives and measures in the Agency Strategic Plan.

http://r20.rs6.net/tn.jsp?llr=fo9sdedab&et=1103894933508&s=425&e=0019EnUJK1V3KNoVAhEyqht09D45LEsr7j4kTlK2DeHy1xb-oijywNN2S-PbZjLTPZ4R4c-tJkQlczZ-dPbdYMHD82DW7muUm-TK237lIXawvqvfxfavkpLXIUd7T8moR9EG0TdRFUIN7vb-eDvpdE93TFpRGURKY4Ie795qFiDUgkTNsETTXdnE8VfD09mVAgoyjc_UQndwNsyrhroaj6-tN1C3ZLvWfBmbErD1EgFljj08XkRqJ-C2cICoLGfmTrrlQYRvrpMXGI=


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7.3. Workplans: Program, Individual Level

At the operational level are the MPCA’s program plans and individual workplans. The MPCA requires individual workplans for every staff member, and links the work in these plans to its strategic goals and objectives. In addition, many of the agency’s 27 programs, though not all, have program workplans, developed annually or bi-annually to identify the work of the specific program for the short term.

Business Plan: the planning bridge

While the MPCA has effectively used the Strategic Plan and workplans, a more effective bridge between the high-level and individual-level plans is needed. The Business Plan is the MPCA’s two to three year plan that bridges this gap by linking the agency strategic goals to program plans and workplans.

In addition to serving as a planning bridge, the MPCA Business Plan provides the framework for agency management to align the work, budget, workforce, and outcomes, and to adapt to change along the way. The Business Plan identifies the agency’s critical areas of focus (focus areas) for the next two to three years, the budget plan that supports the focus areas and other work, and the workforce plan that will help the agency recruit and develop the human resources it needs to accomplish its work. The Business Plan also directs all agency program managers to develop program plans and identifies where those plans will need to incorporate strategies to support the agency’s focus areas, where programs need to continue to implement key strategies, and where programs will have to reduce or eliminate work efforts.

This first version of the business plan identified the activities of Fiscal Years 2011 and 2012 and served as an action plan for the work the agency will do in Fiscal Year 2013. Because it is the agency’s initial plan, it relies upon pre-established fiscal and workforce inputs. Future versions of this plan will actually drive our fiscal, workforce and program decision making. At that point, the agency will have in place a continuous planning cycle of priority-setting, fiscal and workforce planning, program and individual work planning and ultimately implementation. The Business Plan is a living document and will be updated as needed and formally reviewed on a biennial basis. The Business Plan is anticipated to be updated in calendar year 2013.

7.4. Program Specific Planning

The Program Plan sets goals for each program and uses them to evaluate a project’s success and effectiveness. Program goals and details can be found in the program planning documents. At the operational level are the MPCA’s program plans and individual workplans. The MPCA requires individual workplans for every staff member, and links the work in these plans to its strategic goals and objectives. In addition, many of the agency’s 27 programs, though not all, have program workplans, developed annually or bi-annually to identify the work of the specific program for the short term.

7.5. MPCA Business Plan Program Specific Planning

The Program Plan sets goals for each program and uses them to evaluate a project’s success and effectiveness. Program goals and details can be found in the program planning documents. Table 4 shows the 27 identified programs at MPCA which have program plans contained within the MPCA Business Plan.


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Table 4. MPCA Programs Addressed in the Business Plan

Air Ambient Construction Stormwater

Air Point Source Industrial Stormwater

Closed Landfills Municipal Stormwater

Emergency Response Nonpoint Watershed

Petroleum Remediation/Brownfields Surface Water Ambient

Superfund TMDL/Watershed

Voluntary Investigation and Cleanup Groundwater Ambient

Hazardous Waste Community and Business Assistance

Solid Waste Toxics Reduction

Tanks Communications

Feedlots Information Technology

Subsurface Sewage Treatment Systems Data Management

Wastewater (Municipal) Administrative Operations

Wastewater (Industrial)

7.6. Data Quality Objectives

The Data Quality Objectives (DQOs) Process is used to systematic plan for collecting environmental data of a known quality and quantity to support decisions. This guidance describes a seven-step process that is used for developing performance and acceptance criteria that will be used to establish a collection design for a project. The U.S. Environmental Protection Agency (EPA) has written a document that provides guidance on the subject. The document is “Guidance on Systematic Planning Using the Data Quality Objectives Process”, EPA QA/G-4, EPA/240/B-06/001, February 2006. Questions or comments about the Data Quality Objectives Process may be addressed to any Quality Assurance (QA) Coordinator listed on the MPCA Quality System webpage http://www.pca.state.mn.us/index.php/about-mpca/mpca-overview/agency-strategy/mpca-quality-system.html?menuid=&redirect=1.

DQOs are qualitative and quantitative statements derived from the outputs of the first six steps of the DQO process. These statements will clarify the study objectives, define the most appropriate type of data to collect, determine the appropriate conditions from which to collect the data, and specify tolerable limits on decision errors which will be used as the basis for establishing the quantity and quality of data needed to support the decision.

The seven steps used to the DQO Process are used to generate the optimal design for sampling and analytical work. Each step must be used to complete the process, but depending on the site, may or may not be in as much depth. These steps will be clearly described in the Site Quality Assurance Project Plan (QAPP) or Site Work Plan. The QAPP must be approved prior to any work being done on site.

State the problem

The purpose is to clearly define the problem so the focus will be unambiguous. The following steps need to be completed to begin the process.

Identify the members of the planning team. This will be driven by the size and complexity of the problem. There should be representation from all stakeholders. Potential individuals include; samplers, chemists, engineers, modelers, hydrologist, etc.




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Identify the decision maker. The decision maker is the leader of the team. This person has ultimate authority for making final decisions.

Give a concise description of the problem. Describe the conditions and circumstances that are causing the problem. Discuss how they affect human health or the environment, and potential non-compliance with regulation. Describe how the problem is currently understood. If the problem is complex, consider breaking it into pieces.

Specify the available resources and relevant deadlines for the study. Discuss budget, personnel, vehicles, and any other resources that may be used.

Identify the decision

The purpose of this step is to define the decision statement that drives work being done on a site. A decision statement links the principal study question to possible actions that will solve the problem. The principal study question is what is the reason for doing the work? The principle reason for doing the study is to answer a question, such as, “is pollution from the site contributing to groundwater degradation?” After finding the principal study question the different actions that could be taken to answer the question need to be written down such as, “buried solvent barrels on site are leaking and causing the groundwater degradation.”

The last step is to combine the principal study question with the possible actions to form a decision statement. An example from above would be, “determine if solvent barrels buried on site are causing the degradation of the groundwater”. This is a simplified example, but shows the logic involved in developing the decision statement. When several separate decisions are needed, list them, and define what the sequence is in which they must be solved for the site. A flow chart is a possible method of tracking the levels of decisions to be made.

Identify the inputs to the decision

Identify the inputs that are needed to resolve the decision statement and determine which inputs require environmental measurements.

Determine the variables or other information that are needed. Answer questions on whether chemical or physical properties need be studied to answer the decision statement.

Determine the source of the information needed (e.g., historical records, previous data, regulatory guidance, etc.).

Identify the information needed to establish the action level. This could be driven by risk assessment of regulatory thresholds or limits.

Confirm the appropriate analytical methods exist to provide the necessary data. Consider the chemicals of concern and limits that are required to find methods that would be appropriate for measurement.

Define the boundaries of the study

Define the spatial and temporal boundaries that are covered by the decision statement.

Give a detailed description of the boundaries of the problem. This would be physical and temporal (the timeframe when the data are taken).

When appropriate, divide the population into strata that have homogeneous characteristics.

Determine when to collect data. Weather, humidity, time of year, etc., can affect the data.

Define the scale of decision making. This deals with focusing your sampling and analysis in an area that is most affected by your study. For example, the top six inches of soil in children’s play area.


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Identify any practical constraints on Data generation. This includes weather, consent to sample on someone’s property, equipment, time, and personnel.

Develop a decision rule

Define the parameter of interest, specify the action level and integrate previous DQO outputs into a single statement that describes a logical basis for choosing among alternative actions.

Specify the statistical parameter that characterizes the parameter of interest. This means what is to be measured must be defined. Is the mean of the concentrations what drives the cleanup? This may be defined by a regulatory guidance.

Specify the action level for the study. Choose what level would cause a different action. For example, if the soil has <1 mg/kg of a contaminant, the soil is left on site, vs. >1 mg/kg the soil goes to a landfill vs. >50 mg/kg the soil goes to a hazardous waste landfill. Confirm that all action levels can be met by the laboratory analytical methods.

Develop a decision rule. This takes into account the prior steps in the following example. “If the soil (average value from sampling a grid) within the site (defined by the boundaries) is less than the action level (e.g., 1 mg/kg) then take action A (leave the soil in place) else action B (remove the soil).

Specify tolerable limits on decision errors

This step allows the tolerance to be set up for decision errors. This is based upon the consideration of the consequences of making an incorrect decision. This step involves setting the limits on a false positive or false negative and realizing the impacts that these errors could cause. There will also be a gray region that is defined as where the consequences of decision errors are relatively minor. Part of the gray region also deals with the error built into any method, either analytical or sampling, that is used. A planner can go as far in depth as they wish in this step to determine what level of data and number of samples they need to feel confident, they have a site picture that is “good enough”. It is recommended that at a minimum this step should generate the level of analytical data needed, the number of samples needed to have a statistically valid set of data, and the type of sampling needed (e.g., how precise).

Optimize the design for obtaining data

Review the outputs from the prior six steps and determine if they are consistent with the requirements of the site.

Develop the general Data generation design alternatives. These could be simple random sampling, stratified random sampling, systematic sampling, etc.

Select the optimal sample size that satisfies the DQOs for each Data generation design. This includes a cost function of number of samples to total cost of sampling and analysis. If the cost (or other constraint) compared to the needed data do not match, then one of the constraints will need to be relaxed. These include increasing the budget, increasing the tolerable error rates, easing the schedule changing the boundaries, etc.

Select the most resource effective Data generation design that satisfies all of the DQOs. Choose the option that gives the best balance of costs and ability to meet project requirements.

Document the details, theory, and assumptions behind choosing the option to be used in the sampling and analysis plan and in the QAPP. An experienced statistician can review the results of the work and make suggestions that could reduce the sample load or costs in other areas.


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The DQP process is iterative and may take several iterations to determine the best course to take. Each time the evaluation of the potential methods of site work or laboratory analysis will get more detailed. The MPCA’s DQOs are regularly updated by agency QA staff and is available online http://www.pca.state.mn.us/index.php/view-document.html?gid=5471.

7.7. Quality Assurance Project Plans

For individual projects, development of the QAPP is the practical application of the systematic planning process. The QAPP itself is then the product and documentation of the systematic planning process. Use of a QAPP ensures thorough development and documentation of the Systematic Planning Process and method of assessment of work. No Data generation activities or use should begin until there is an approved QAPP. There are various forms of QAPPs throughout the agency in the form of program plans down to site specific QAPPs. In some programs, the overall QAPrP is used as the basis for site work.

The basic requirements of a QAPP followed by MPCA are outlined in the EPA document EPA QA/R–5 EPA Requirements for Quality Assurance Project Plans and the MPCA QAPP Guidance Document.

For individual projects, development of the QAPP is the practical application of the systematic planning process. The QAPP itself is then the product and documentation of the systematic planning process. Use of a QAPP ensures thorough development and documentation of the Systematic Planning Process and method of assessment of work. No data collection activities or use must begin until there is an approved QAPP. There are various forms of QAPPs throughout the agency.

Table 5. MPCA Programs That Require QAPPs

Program QAPP Development QAPP Review QAPP Approval

Closed Landfill Program† MPCA QAC/Staff MPCA QAC / PM Uses SAPs

Superfund - State Sites RP Contractor MPCA QAC / PM MPCA QAC / PM

Superfund - Federal Sites RP Contractor MPCA QAC / PM and EPA MPCA QAC and EPA

Superfund – Federal Program DOD Contractor

MPCA QAC / PM and EPA MPCA QAC and EPA

RCRA – State Program MPCA QAC / Staff MPCA QAC / PM MPCA QAC / PM

RCRA – Sites RP Contractor MPCA QAC / PM MPCA QAC / PM

TSCA – PCB Inspections MPCA QAC / Staff MPCA QAC / PM and EPA MPCA QAC / Lab Manager and EPA

NPDES - Program wide MPCA QAC / Staff MPCA QAC / PM and EPA MPCA QAC / Lab Manager and EPA

Pollution Prevention (P2) MPCA QAC MPCA QAC / PM MPCA QAC/ PM and EPA

Surface Water MPCA QAC / Staff MPCA QAC / PM and EPA MPCA QAC / Lab Manager and EPA

Biological Monitoring MPCA Staff MPCA QAC / PM and EPA MPCA QAC / Lab Manager and EPA

Sediment MPCA Staff MPCA QAC / PM and EPA

MPCA QAC / Lab Manager and EPA / GLNPO

Air Toxics/Metals MPCA QAC / Staff MPCA QAC / LM MPCA QAC / Lab Manager

PM2.5 Monitoring MPCA QAC / Staff MPCA QAC / LM and EPA MPCA QAC / Lab Manager and EPA

UST / LUST MPCA QAC / Staff MPCA QAC / PM and EPA MPCA QAC and EPA

GLRI MPCA Staff/QAC MPCA QAC / PM and EPA MPCA QAC and EPA






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The Closed Landfill Program (CLP) uses a Sampling and Analysis Plan which also contains the relevant SOPs. A separate SOP has been developed for collecting methane gas readings at gas probes, flares, and gas extraction wells. Virtually all monitoring well sampling is subcontracted to consultants.

The Pollution Prevention (P2) Program has a QAPP for bisphenol A (BPA) projects. For other P2 projects the QAC writes a project-specific QAPP for projects funded by EPA and for which EPA requires a QAPP.

When a Quality Assurance Project Plan required

A QAPP is a required planning document for projects that involve the generation and/or use of environmental information - generally thought of as environmental data. These environmental information projects are mostly traditional sampling and analysis projects. However, many other types of work are considered environmental information projects and require QAPPs such as the use of secondary data in decision-making. The basic requirements of a QAPP followed by MPCA are outlined in the EPA document EPA QA/R-5 EPA Requirements for Quality Assurance Project Plans.

Other types of environmental projects that typically require a QAPP include Modeling projects; Environmental Technology Design, Construction, and Operation projects; Wetlands and Habitat Restoration projects; Data Quality Assessment, Verification, Validation, or Analysis projects or processes; Geospatial Data use projects; Bio-monitoring projects; and Pollution Prevention (P2) projects.

Secondary Data

Secondary data is data collected by someone other than the data user. Some examples of secondary data that may be used for an environmental project include maps, plots, photographs, GIS data, land surveys, volunteer monitoring data, laboratory analyses, field analyses and measurements, biological samples or analyses, peer review information, and historical data from previous relevant projects conducted in the same general geographical area.

Quality Assurance Project Plan Development Process

The environmental project QAPP is typically written by the MPCA QA/QC Coordinator responsible for the medium (land, water, air) to be assessed. Much of the information needed to write the QAPP is contained in the project Work Plan which the QAC uses to develop the draft QAPP. The QAC contacts the MPCA Project Manager (PM) for any necessary information that is not contained in the Work Plan. The PM either provides the additional information or contacts the appropriate project staff for it. Following completion of the draft QAPP the QAC submits it for review and comment to the PM, the PM’s supervisor, project staff, the project consultant, if used, and any others with significant project responsibilities such as modelers, if used, and to other interested parties, upon request. The QAC then makes any necessary QAPP changes after which it is ready for signatures. The QAC, PM, and PM’s supervisor then sign the QAPP after which it becomes the project quality document. Additional project staff such as the consultant, if used, or the modeler, if used, or other staff with specific extraordinary project-related expertise, if used, may also sign the QAPP. In addition to the QAPP, the QAC is also responsible for writing the project SOPs and keeping them up to date.

The QAC is responsible for overall project quality implementation in accordance with the QAPP. The QAC may also become engage directly with project quality-related activities such as field sampling activities, analytical laboratory audit, and data assessment, and resolution of quality-related issues. However, all project staff are responsible for quality implementation whenever they are engaged in project or project-related activities and following the applicable SOPs such as sampling methods, sample handling methods, observance of analyte holding times, and standardization of field instruments. Any deviations from the project SOPs are documented and become part of the project record. Project-relevant SOPs are often included in the project QAPP as appendices.

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The PM is responsible for primary overall project oversight and coordination and typically spends significant time in the field. The PM is also responsible for data review, verification, and validation.

A consultant, modeler, or other with specific skills required by the project has specific project duties and responsibilities which are clearly defined in the project Work Plan and QAPP.

Any significant project changes that occur before project completion such as a PM change, a significant monitoring change (sampling personnel, sampling sites, sampling frequency, sample analytes), or analyzing laboratory change requires a QAPP revision. The QAC makes these necessary QAPP changes with the modified QAPP becoming revision 1. The revised QAPP is then signed and the original QAPP archived.

U.S. Environmental Protection Agency Uniform Federal Policy for Quality Assurance Project Plan

The Uniform Federal Policy for Quality Assurance Project Plans (UFP–QAPP) is a consensus document that provides instructions for preparing Quality Assurance Project Plans (QAPPs) for any environmental data collection operation. QAPPs written in the UFP format integrate all technical and quality aspects of a project, including planning, implementation, and assessment. A QAPP written in the UFP format will contain information that may previously have been presented in a work plan or field sampling plan. Formerly, environmental quality assessment has focused primarily on analytical laboratory performance. The UFP–QAPP format also addresses sampling plan design adequacy, field sampling activities, and data review with emphasis on data quality in the context of the decisions to be made based upon that data. A QAPP prepared and approved according to UFP-QAPP meets all the requirements of (QA/R-5), EPA Requirements for Quality Assurance Project Plans.

7.8. Data Quality Improvement Planning

The development of data quality improvement efforts are, in part, directed by the agency’s 2007 Progressive data management strategy. This strategy establishes the goal of having governed data and data systems that enables organizational leaders to make data-driven decisions with confidence. The Data Services Section is working to insure data governance and is partnering with the Environmental Data Quality Section Environmental Data Quality Section Unit uses experience and framework within the remediation data QA Program to build a more comprehensive enterprise-wide data quality program.

Further work includes the Green Data project (described earlier in Section 6.2). The goal of the QA unit is to ascertain the level of quality of the thousands of data points within the databases at MPCA. These data come from a variety of sources and programs and are routinely used in decision making. Most of the data is from direct MPCA sampling or oversight. Therefore, the QA unit is working to establish a QA grading on these data to better understand the level of trust that can be placed in the data for use in environmental decision making.

7.9. Environmental Performance Partnership Agreement

The Environmental Performance Partnership Agreement (EnPPA) is the primary mechanism through which the MPCA conducts its planning with EPA Region 5. The EnPPA is a subsystem of the National Environmental Performance Partnership System (NEPPS), which was developed by EPA and the Environmental Council of States (ECOS) to enhance planning efforts for the states and EPA. The EnPPA is an agreement between the MPCA and Region 5 EPA that lists the programmatic activities that will take place in Minnesota over a Four-year period. It is a tool designed to help prioritize activities, measure environmental success, improve communications, and facilitate a holistic approach to environmental protection.


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The EnPPA serves as a coordination tool between the MPCA and EPA and defines their mutual environmental and operational responsibilities. The MPCA also uses a Joint Evaluation Report to track its progress in fulfilling its responsibilities as specified in the EnPPA.

The EnPPA describes the MPCA and EPA programmatic commitments and provides details on environmental goals, objectives, and environmental outcome measures. The goals and objectives emphasize environmental outcomes and are supported by environmental outcome measures. The programmatic details describe the specific activities that both agencies conduct to achieve their goals. These program activities cover the following functional areas:

Permitting

Assistance

Compliance Determination

Enforcement

Monitoring and Evaluation

Remediation

Policies and Rules

Program Specific Activities

Environmental outcome measures form the framework since they can both help set direction and evaluate progress. Outcome measures can also help decision-makers assess environmental conditions and trends, enabling them to better direct the agency’s future course. They can also be used as an evaluative tool to track environmental progress.

The overall goals of the MPCA are defined within the Strategic Plan (reference section here) which defines Agency direction and long range planning. Specific programs are defined within the business plan which overlap the EnPPA as it refers to specific program goals and objectives. The Programs define their goals and objectives are referenced within the business plan. The goals and objectives are updated every two to three years by the programs. The program goals tie to the EnPPA through agreed upon goals by the EPA and MPCA. Specific programs are listed in the MPCA Business Plan Program Specific Planning section 7.5.


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Figure 8 The MPCA Monitoring – Data – Information Cycle

The process is iterative in that each monitoring effort helps refine future efforts. The process of identifying and filling information needs has several related steps as indicated in the preceding Monitoring – Data – Information Cycle diagram. The MPCA currently conducts monitoring, either directly or through permit or rule requirements, in three media: air, surface water, and groundwater. The MPCA also conducts some soil and sediment sampling and habitat characterizations, but these land activities are generally done in conjunction with groundwater or surface water monitoring efforts.

The MPCA’s environmental monitoring efforts are categorized according to the way the information is assessed and used. In general, these types are condition monitoring, problem investigation monitoring, and effectiveness monitoring. Condition monitoring identifies environmental status and trends by examining the condition of air, groundwater, and surface water resources. Problem investigation monitoring involves investigating specific problems to enable development of a management plan to protect or improve the resource. Problem investigation monitoring is used to determine causes and sources of an identified problem. Effectiveness monitoring is used to determine the effectiveness of specific regulatory or voluntary management actions taken to remediate environmental problems. At the MPCA, most condition monitoring is conducted by the Environmental Analysis & Outcomes (EAO) Division. Most problem investigation and effectiveness monitoring are conducted by the Remediation, Municipal, and Watershed Divisions.

7.10. Water Quality Planning and Management using a Watershed Approach

The MPCA established a goal to assess the condition of Minnesota’s waters via a 10-year cycle, followed by development of water quality protection and restoration strategies, and implementation efforts. The key approach taken to achieve this goal focuses on the 81 major watersheds (Figure 9) in the state, at the eight-digit hydrologic unit code (HUC) level, and is called the Watershed Approach. Water resource management by watersheds is an established organizing concept in Minnesota. Provisions of the Minnesota Clean Water


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Legacy Act (CWLA) provide additional support to this approach by creating a framework for organizing and scheduling work, and for engaging partners and stakeholders.

Figure 9 Intensive Watershed Monitoring Map

A watershed is the area of land that all drains to the same body of water. The Watershed Approach intensively monitors streams and lakes within a major watershed to determine the overall health of the water, identify impaired waters, and identify waters in need of additional protection efforts to prevent impairments. Follow-up monitoring is then done in impaired sub-watersheds to determine the cause(s) of the impairments (the “stressors” impacting the biological community) and to identify pollutant sources. Lastly, a restoration (TMDL) or protection strategy and implementation plan is written for the watershed so that partners can begin best management practice improvements.

The intensive nature of this type of monitoring (i.e., the good coverage of sites within the watershed) leads to one of the significant benefits of the approach – the identification of most, if not all, of the impairment problems and protection needs at one time. This allows for an opportunity to address needs in a watershed through a coordinated strategy development process. This is much different than past monitoring, when limited monitoring resources were not concentrated in defined areas. As a result, MPCA often identified some impairments in an area during one year, and additional impairments at the same site in later years, necessitating a separate TMDL study or slowing the progress of the one underway. The Watershed Approach is intended to prevent this from occurring through more comprehensive monitoring and assessment, and enabling the development of watershed-wide studies addressing both protection and restoration needs.

The Watershed Approach also provides predictability in the monitoring schedule. By establishing a schedule for monitoring all the state’s major watersheds every 10 years, the state can accomplish the following:

Provide advance notice to interested stakeholders, local governments and volunteers regarding monitoring plans.

Assist local groups in ramping up their monitoring efforts to provide data in advance or in between agency monitoring efforts.

Provide stakeholders a heads up as to when they can expect the TMDL study and protection strategy work to begin in their area.

Ensure that comprehensive information on the status of water quality – and water quality management efforts – is collected, evaluated and provided to state and local partners at least once each decade.

Because unique water management needs exist and change over time, the agency will use adaptive management principles to recognize when water management activities may be better addressed at the

http://www.pca.state.mn.us/images/stories/water/watershedmap-intensivemonitoringcycle-big.gif


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basin, minor watershed or water body/segment levels. Adaptive management entails a plan-do-check cycle whereby after implementation has proceeded for a time, re-assessment is performed and adaptations are made in the successive cycle to optimize actions and results. In the TMDL context, the agency will use adaptive management as part of its implementation process. Adaptive management will be used to ensure that implementation activities are focused on achieving the reductions necessary to achieve compliance with TMDL requirements as efficiently as possible. The MPCA believes that a flexible and focused approach to implementing TMDLs will ensure that impaired waters are restored as efficiently as possible.

Watershed approach process

The Watershed Approach is a 10-year rotation for assessing waters of the state on the level of Minnesota’s major watersheds. The primary feature of the Watershed Approach is that it provides a unifying focus on the water resource as the starting point for water quality assessment, planning, and results measures. This approach may be modified to meet local conditions, based on factors such as watershed size, landscape diversity and geographic complexity (e.g., Twin Cities metro area).

The overlapping steps of the Watershed Approach are as follows, with the goal of completing Steps 1 through 3 within four years of initiation in each watershed and Step 4 starting in the fifth year:

Step 1 — Monitor and gather data and information

The MPCA uses an intensive watershed monitoring schedule that provides comprehensive assessments of all major watersheds on a ten-year cycle. This schedule provides intensive monitoring of streams and lakes within each major watershed to determine overall health of the water resources, to identify impaired waters, and to identify those waters in need of additional protection to prevent future impairments. Data from past and current local water monitoring are included in the process. Information on watershed characteristics, like land use, topography, soils, and pollution sources is also gathered in this step.

Step 2 — Assess the data

Based on results of intensive watershed monitoring in step one, MPCA staff and its partners conduct a rigorous process to determine whether water resources meet water quality standards and designated uses. Waters that do not meet water quality standards are listed as impaired waters.

Step 3 — Establish implementation strategies to meet standards

Based on the watershed assessment, a TMDL study and/or protection strategy is completed. Existing local water plans and water body studies are incorporated into the planning process. An overall water quality framework which details strategies and methods for meeting water quality standards is developed for each watershed with input from interested parties.

Step 4 — Implement water quality activities

Included in this step are all traditional permitting activities*, in addition to programs and actions directed at nonpoint sources. Partnerships with state agencies and various local units of government, including watershed districts, municipalities, and soil and water conservation districts, will be necessary to implement these water quality activities.

*MPCA will continue routine regulation during all steps of the watershed approach process, as appropriate.

The MPCA’s improved system for integrating and managing water quality programs will yield considerable benefits in the form of efficiencies and environmental benefits, including:

An ongoing, predictable cycle for water quality management and evaluation.

Integrating watershed protection and restoration needs into a single management plan.

A more efficient approach to addressing impairments.


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A common framework for monitoring, TMDL studies, and implementation strategies.

Increased stakeholder interest and local support.

Improved collaboration and innovation.

A reduction in the cost of improving the quality of waters.

Local basin planning

There are different levels of water planning that occur concurrently and build upon each other. Each address issues at different levels as appropriate. Plan outreach and organization will be conducted at the basin level. Basin plans will address all the major drainage basins in the state. They will consider the cumulative impacts on the main stem/receiving water of all of the watersheds in the basin. Local water plans are prepared by counties, watershed districts, and watershed management organizations. Local plans deal with the jurisdiction of the entity preparing the plan and focus on local problems.

In summary, local plans deal with local issues, typically on the scale of a water body, minor watershed, or sometimes on a major watershed. They do not typically go beyond their own political boundaries to consider cumulative impacts on other jurisdictions. Basin plans are done on a hydrologic basis and help integrate local plans to address cumulative impacts of multiple watersheds and political jurisdictions on the basin’s main stem/receiving water.

Watershed-based planning

Water quality planning occurs at several levels in Minnesota; with each level funneling into Watershed Restoration and Protection (WRAP) Strategies. Local water plans are prepared by counties, watershed districts, and watershed management organizations. Local plans deal with the jurisdiction of the entity preparing the plan and focus on local problems. The Watershed Approach now utilized by the MPCA, will integrate local water plans into WRAP Strategies, along with other data acquired at the state agency level (e.g., monitoring and assessment). WRAP strategies will act as the primary planning vehicle to drive implementation efforts in targeted areas.

http://www.pca.state.mn.us/index.php/water/water-types-and-programs/surface-water/watershed-approach/watershed-management-plans.html.

Because local involvement is vital to the success of water quality planning and management, civic engagement is a central focus in WRAP strategies; ensuring that community members are involved in making the decisions that impact them directly. A goal of civic engagement is to encourage local leaders to create a watershed study and implementation plan that reflects the unique circumstances within their communities.

Minnesota’s Water Quality Monitoring Strategy describes the 10-year plan for monitoring surface and groundwater. http://www.pca.state.mn.us/index.php/water/water-monitoring-and-reporting/water-quality-and-pollutants/minnesota-s-water-quality-monitoring-strategy.html?menuid=&redirect=1.

8. Quality Implementation of Work Processes

This Chapter of the QMP describes the processes used at the MPCA for facilitating the effective implementation of QA plans and procedures which comprise MPCA’s Quality System. Any changes to the QMP will be documented in revisions and approved in the same process and concurrence as the QMP is. As with the QA planning described in Chapter 7, implementation of QA procedures takes place at the Agency, Program, and project levels.

http://www.pca.state.mn.us/index.php/water/water-types-and-programs/surface-water/watershed-approach/watershed-management-plans.html

http://www.pca.state.mn.us/index.php/water/water-types-and-programs/surface-water/watershed-approach/watershed-management-plans.html

http://www.pca.state.mn.us/index.php/water/water-monitoring-and-reporting/water-quality-and-pollutants/minnesota-s-water-quality-monitoring-strategy.html?menuid=&redirect=1.

http://www.pca.state.mn.us/index.php/water/water-monitoring-and-reporting/water-quality-and-pollutants/minnesota-s-water-quality-monitoring-strategy.html?menuid=&redirect=1.


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The MPCA manages the implementation of quality management using the tiered approach. Management, project managers and QA staff insure the QMP, Work Plan, QAPPs, SOPs and other guidance is adhered to. The MPCA programs will provide technical oversight for implementing environmental data operations through the development of QAPrPs.

8.1. MPCA Quality Implementation

The QA at the MPCA is largely implemented through QAPPs and other quality documentation management tools under the blanket of the agencies QMP and work of the Environmental Data Quality unit (which contains the Agency QACs). The MPCA has many unique sections with individual requirements, statutory guidelines, rules, and policies that must be followed. Quality management at the unit level should incorporate the unique qualities that are specific to each unit and subsequent program. Consequently, QA/QC is managed first at the Program level, and more specifically on a project-by-project basis using QAPPs at a project level and required data assessment activities.

The Quality Management System is implemented largely through the following agency functions:

Ensure QAPPs are in place for all applicable agency work.

Training (technical training per unit needs and QA/QC training).

Adherence to QAPPs (both for internal and for external partners).

Clearly defined supervisor roles

MPCA QA/QC Unit oversight and assistance staff meet as applicable to address: - quality documentation status - quality audits of laboratories and contractors - continuous improvement efforts

Each of these systems is discussed in more detail in the appropriate section within this document. This document officially establishes these requirements as components of MPCA’s QMP.

The goal of the MPCA’s QMP and other quality guidelines is to insure the highest level of integrity and quality of data for decision making.

8.2. The Implementation of Quality Assurance Plans and Work Plans

The MPCA Project Manager monitors the quality of the MPCA project or site work against the requirements of the Work Plan or QAPP. As the work proceeds, the MPCA Project Manager reviews the work being done to ensure the DQOs, QAPP, and Work Plan are being followed. The QAPP also specifies appropriate laboratory analytical procedures. If a MPCA-contracted laboratory is used, it must be certified by MDH or other approved authority by the State. If a mobile laboratory is used, it must meet specific requirements, which may be found on the MPCA QA webpage at http://www.pca.state.mn.us/programs/qa_p.html. Analytical data from mobile laboratories are used only for on-site analytical screening purposes. Major corrective actions require the MPCA Project Manager’s approval. Superfund sites also require EPA Remedial Project Manager approval. After the work is completed, it is documented in the final report. The MPCA Project Manager verifies that the site DQOs have been met, that all site work has been completed, and approves the final report. The QA section of the report is often submitted to the QAC for review and approval.

8.3. Standard Operations and Procedures (SOPs)

All sampling and analytical procedures are documented in the SOPs and the MPCA sampling guidance documents. The MPCA writes SOPs for critical tasks that merit standardization. The program QAC typically writes the SOPs with input from knowledgeable staff. The QAC gives the SOPs final review and approval.

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Outdated SOPs are updated and rewritten. The QAC also reviews and approves the updated SOP as appropriate. The SOP format may be found in Section 2.5.

8.4. Sampling Guidance

Written sampling guidance enables standardization of sampling techniques that helps ensure data quality. The guidance helps ensure a contractor or consultant understands the sampling method and QA that must be an integral part of it. MPCA technical experts write the guidance documents, which are then reviewed by knowledgeable internal and external peers, approved by QACs, then released to the public. The MPCA may hold public comment and training sessions following release of the guidance document to answer questions and educate end-users. For example, the Petroleum Remediation Program has program specific sampling guidance documents. These guidance documents may be found on the internet at: http://www.pca.state.mn.us/bkzq810.

8.5. Policy Documents

The MPCA staff writes policy documents to ensure the use of appropriate standard sampling and analytical procedures. Management scopes these documents with staff and provides input and final approval of all published policies. Typically, policy documents are more general in scope and identify objectives and issues. QACs provide more specific guidance on QA issues, if needed. A policy document may state acceptable state-specific methods for resolving problems, analyzing samples for parameters for which standard methods have not been established, or ambiguous sampling or analytical methods. The MPCA issued a policy to resolve the confusion and clearly define acceptable method application in Minnesota. A policy is not a state rule but is valid as a commonly-used practice in Minnesota. A consultant or private party must follow agency policy to help ensure its work is approved upon review by MPCA staff. Upon completion and publishing of the Agency Policy, specific internet sites are updated with new policies, interested parties are informed of the changes through a variety of methods (such as public meetings, press releases, memorandums, etc) and the policy goes into effect on the date stated.

9. Quality Assessment and Response

This Chapter of the QMP describes how MPCA assesses its Quality Management System. A site assessment is based upon an objective set of standards and is conducted before work may begin on a project or at a site. It may be done internally or externally. An internal assessment is conducted by a MPCA assessor or auditor or one contracted by MPCA to review or audit a specific site, program, or project. MPCA internal assessments include management review, peer evaluation, and technical review. An external assessment is one typically conducted by EPA, the State Legislature, a private organization, or another agency.

9.1. Management System Reviews (Technical Audits)

The QACs may conduct an internal agency Quality System Review between successive QMP revisions. Normally these are done specifically on environmental data or the data gathering process by the QACs when requested by the programs or when an error is reoccurring. The overall auditing of Agency operations is performed within the Operational and Strategic Reviews as described in prior sections.

EPA QA staff may conduct an external audit of the MPCA quality system. The external audit is pre-announced and has an agreed-upon scope to ensure that both the EPA and the MPCA are acutely prepared for it. The audit was formally referred to as a Management Systems Review (MSR) but is more in line with a technical audit (see EPA QA/G-7 http://www.epa.gov/quality/qs-docs/g7-final.pdf) and is conducted after the QMP is finalized.

http://www.pca.state.mn.us/bkzq810

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Additional audits are conducted at MPCA by the EPA Air Division Legislative Auditors on specific programs or projects. Other types of audits are internal reviews and audits based upon performance management of programs (such as continuous improvement programs). These audits are used to inform program or Agency management of the current status of a program or project in order that informed decisions can be made on resources and emphasis of work. The corrective actions post audits are outlined in the Audits Corrective Action Process outlined in Figure 10. The Audit Corrective Action Process.

Figure 10. The Audit Corrective Action Process

Audits conducted by the QACs or other agency staff depends upon the program or project needs, the audit focus and scope, audit staff availability, auditing experience, and knowledge of the program or project to be audited. The audit type to be conducted is typically one of the following: data quality, data assessment, performance evaluation, surveillance, technical systems, inspection, or self–assessment. The audit may also be comprised of elements of two or more of these audit types depending upon audit purpose.

The audit type selected is based upon program or project importance and complexity and the consequences of making erroneous decisions and conclusions based upon the data generated. This is to say that the graded approach is applied during the audit process; the greater the need for data of the predetermined quality and quantity, the more extensive and thorough the audit.

Following audit completion the findings of all auditors are combined into one preliminary report that is comprised of both satisfactory findings and deficiencies. The report is then compared to the audit checklists to ensure all applicable audit elements have been satisfactorily addressed. The report is then shared with the project or program manager to ensure there are no auditor errors, misunderstandings, explanations, clarifications, or additional information that would make a perceived deficiency moot. It also affords the manager the opportunity to offer a time frame within which each deficiency may be resolved. The auditors then meet to collectively determine the courses of action to be taken to remedy the deficiencies. Deficiencies deemed to be urgent, e.g., those that may have serious human health or environmental implications, are addressed immediately.

The audit team also identifies deficiencies that are sufficiently egregious to merit a follow–up audit. Although the manager is responsible for determining the remedial courses of action, these are typically shared with the audit team to help ensure a satisfactory resolution of the deficiencies.

The corrective actions must address and correct each significant deficiency, investigate and identify its cause(s), implement actions and/or strategies to help prevent its recurrence, and specify a date acceptable to the audit team by which the deficiency will be corrected.

Group Findings for Common Causes

Examine Each Group for

Underlying Causes

Conduct Audit

Develop Actions to Correct

Underlying Causes

Analyze Exceptions for Cause and Effect

Fix Problems

Identify Problems

Improve Environmental Management

System Effectiveness


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9.2. Audits and Surveillance

The Minnesota State Legislature is authorized to audit MPCA programs. The Legislative Auditor has authority to access, review, and assess all MPCA program records and documents to evaluate the programs’ progress toward achieving their goals and effectiveness at meeting their objectives. The auditor’s efforts are typically focused on major MPCA programs.

Smaller MPCA programs that the Legislative Auditor elects not to audit may be audited internally by the appropriate MPCA QAC or externally by personnel with the appropriate technical expertise. The audit may assess the program’s progress toward achieving its goals, its effectiveness at fulfilling its stated mission, and the quality of its work product.

The audit report contains valuable information and recommendations about the program’s strengths and deficiencies and may serve as a constructive guide for MPCA management and staff for program improvement. Typically, the MPCA Commissioner, the recipient of the completed audit report, delegates to the Executive Team the authority to determine the appropriate actions to remedy the deficiencies noted in the audit. Program managers and supervisors are assigned the responsibility of implementing the remedial actions mandated by the Executive Team. Managers and supervisors monitor their program’s progress at resolving the deficiencies until all have been resolved. The Executive Team receives regular progress reports while the deficiencies are being remedied. The Legislative Auditor receives a comprehensive report following resolution of all deficiencies noted in the audit.

As an example, a QAC may audit analytical data from sampling done at federal and state sites (for example, the Twin Cities Army Ammunition Plant, a (ERIS Superfund site). At the TCAAP site data were validated before entry into the IRDMIS data system. The QAC could audit the data at the laboratory or request that it be submitted to the MPCA office for review. The QAC compared the reported data with the raw data to ensure that the analyte concentrations are accurately reported. The audit followed the format of the Contract Laboratory Procedures National Functional Guidelines (NFG). The NFG is a methodical approach to reviewing data from the CLP program. It is modified for overall quality review of standard data sets in that all parts of the data are reviewed, from sample delivery to the laboratory (chain of custody) to extraction, analysis, data interpretation, and data reporting. The QAC then wrote an audit report that includes the data audit and flags data, when necessary, using EPA CLP like flags. Flagged data are noted as being biased, rejected, nondetect, or usable as reported. The audit report was placed in the site files for future reference.

Other types of assessments include, but are not limited to:

staff visit to a site to review work in progress

unannounced contract laboratory audit

PE sample submittal to laboratory

staff programmatic oversight work

staff quality review of submitted documents

Specific QAC audits may include:

site, project, or program DQO data audit

site field sampling audit

consultant QAPP compliance audit

laboratory QAPP audit

contract compliance audits

Such audits may detect deficiencies requiring specific site, program, or laboratory corrective actions. They are crucial to verifying that all required protocols are being followed. When audits are not conducted, errors may occur, go undetected, compromise site or program DQOs, and require re-sampling or program


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redesign. Unresolved errors may corrupt data sets and render data useless. This is further discussed in Section 10.6.

9.3. Data Quality

High quality data in itself, does not guarantee good decision-making. Good decisions are best made through the establishment and adherence to Data Quality Objectives (DQO) or similar strategies, which the MPCA uses to implement the proper approach to resolution of potential environmental problems. MPCA works constantly to ensure the highest quality data is used that is available for decision making in programs and site work. QACs review data or train staff on data review to assist in ensuring data quality. When questions arise QACs track issues back to sampling staff or laboratories as necessary to ensure data is maintained at a high level of quality. Updates are made to databases to screen data for issues and alert data users prior to decision making. This is an ongoing process that continues to ensure the best data available.

9.4. Data Quality Assessment

DQA evaluation criteria vary by program. For example, the Superfund Program not only specifies sampling procedures but methods of preparing the site for sampling (such as purging a well). This is detailed in the MPCA guidance document Risk-Based Site Evaluation Process Guidance Documents found at http://www.pca.state.mn.us/cleanup/riskbasedoc.html. This document describes specific procedures for groundwater sampling, soil sampling, surface water sampling, setting background levels, air monitoring, sediment sampling, and sampling QA/QC. Other programs have similar documents. The particular needs and requirements of each program are considered when preparing these documents.

The Project Manager, technical staff, Hydrologist, Soil Scientist, or QAC performs the data review depending on its use as specified in the DQO.

The MPCA data quality assessment program consists of activities designed to assess the performance or effectiveness of a specific project or program. The following guidance documents are available on the MPCA Quality System’s external webpage: http://www.pca.state.mn.us/index.php/about-mpca/mpca-overview/agency-strategy/mpca-quality-system.html?menuid=&redirect=1.

Laboratory Quality Control and Data Policy

Laboratory Data Checklist Guidance

Laboratory Data Review Checklist

9.5. Laboratory Audits

System audits are typically conducted as part of a corrective action or when a significant problem is identified or suspected. MPCA QACs may conduct contract laboratory and NPDES laboratory quality systems audits to ensure procedures and analytical methods produce high-quality data for MPCA projects and programs. The MDH Environmental Laboratory Accreditation Program, or other certifying authority, perform environmental laboratory audits to ensure that accredited laboratories can produce accurate and precise test results.

Before the MDH Environmental Laboratory Accreditation Program was implemented in 1989, the MPCA Water Quality program QAC conducted numerous NPDES laboratory quality systems audits. MDH inspects certified laboratories every two to three years; therefore, the number of QAC laboratory audits has been significantly reduced. MPCA recently has taken over registration of waste water (NPDES) laboratories and small water labs. This program is being developed over 2013. The program will require laboratory audits every three years, with documentation review, yearly PT standards reviewed, and training given to the laboratories to maintain high data quality.

http://www.pca.state.mn.us/cleanup/riskbasedoc.html




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MDH Lab Certification

The MPCA relies upon the MDH Environmental Laboratory Accreditation Program or other programs to help ensure that certified laboratories providing analytical services for MPCA generate reliable data of known quality for commercial laboratories. Accreditation from MDH is available for the following programs: Safe Drinking Water Program (SDWP), Clean Water Program (CWP), Underground Storage Tanks (UST), and Resource Conservation and Recovery Act (RCRA). MPCA has taken over the CWP through a registration program that goes into effect on January 1, 2013. More information can be found on the Lab Registration webpage.

Minn. R. Ch. 4740 requires that laboratories providing analytical services for the SDWP and CWP be certified or approved. In 1991, the MPCA required that laboratories providing analytical services for NPDES permittees be reviewed and approved. The MDH Environmental Laboratory Accreditation Program rules, statutes, and a list of accredited laboratories may be found on the MDH website at http://www.health.state.mn.us/divs/phl/cert.html. Following is a summary of MDH accreditation requirements.

Contract Labs Audits

Laboratories with which the MPCA has contractual agreements are subject to audits. The audits are coordinated with the laboratory manager who typically accompanies the auditors to direct them to laboratory areas or activities of interest and to answer questions. Following the audit the MPCA QACs or other knowledgeable staff holds an exit interview with the laboratory manager to discuss any problems documented on the audit checklist, the required actions to remediate them, and a timeline by which the problems must be resolved. The auditor may conduct a follow–up audit to verify that the required corrective actions have been done. A copy of the audit results is sent to the laboratory which is typically given 30 days to respond to any deficiencies noted. The laboratory must document all corrective actions taken to correct the deficiencies. An unannounced follow–up audit may be conducted if the corrective actions taken are deemed inadequate, problems or deficiencies remain unresolved, or inadequate documentation is submitted to MPCA audit staff.

The laboratory must submit a complete and accurate application for its initial base certification and for certification renewal. An SOP must be submitted for all parameters and methods for which it is seeking certification. It must submit a revised SOP whenever a method is modified or updated. The laboratory must submit a complete laboratory Quality Assurance Manual (QAM) for the initial base certification and for certification renewal. It must submit a revised QAM whenever procedures are modified or updated.

A laboratory receives certification for a time period of two years. Each laboratory receives a complete on-site inspection and audit for the initial base certification and is audited at least once every three years thereafter. A laboratory must successfully complete a Proficiency Test (PT) Study or Water Pollution (WP) Study demonstrating analytical proficiency for all its certified parameters annually A laboratory must use the QA practices specified in the Certification Rule A laboratory must maintain records as specified in the Certification Rule A laboratory may pursue certification for analytical methods of the Safe Drinking Water, Clean Water, RCRA, and UST Programs.

Guidance for the laboratory audits can be found on the MPCA’s Laboratory Data Review Checklist Guidance found at http://www.pca.state.mn.us/index.php/view-document.html?gid=16113.

Air Monitoring Audits

The MPCA conducts system audits of industrial air monitoring networks to ensure compliance with EPA and MPCA air monitoring regulations. Audits are conducted as needed based upon site-specific issues. Each air

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point is audited at least yearly within the MPCA air program and often multiple times a year based upon

federal code found at 40 CFR 58 G.

The Minnesota Pollution Control Agency (MPCA) monitors outdoor air quality throughout Minnesota. There are many reasons to monitor the quality of our outdoor air. The data collected by the MPCA helps determine major sources of ambient air pollution in Minnesota, addresses ways to reduce pollution levels, and tracks concentrations of ambient air pollution over time. Data are also used to determine compliance with National Ambient Air Quality Standards (NAAQS) and whether we are protecting the public from the harmful health effects of ambient air pollution.

The purpose of this annual report is to demonstrate compliance with air monitoring network regulations, to describe proposed changes for the upcoming year, and to provide specific information on each of Minnesota's existing and proposed air quality monitoring sites. Details regarding the location of individual sites, monitoring objectives, and proposed changes are provided. Data for several pollutants are summarized to show current conditions relative to State and Federal air quality standards. The plan also provides an overview of the various air quality monitoring networks operating in Minnesota. More in the MPCA air monitoring network and the audit program at

http://www.pca.state.mn.us/air/monitoringnetwork.html

9.6. Laboratory Performance Evaluation

The MPCA contract laboratory performance may be assessed through its analysis of performance test (PT) samples of known concentration. The samples are from one of three sources: commercially obtained, provided by QA staff, or site samples containing a known amount of target analyte.

The MPCA Water Quality programs may submit blind PT total phosphorus samples to laboratories participating in Clean Water Partnership (CWP) projects funded by the MPCA. Phosphorus was chosen as the parameter to be analyzed because of its importance in CWP decision-making. The QAC tracks any PT deficiencies noted to ensure they are remedied. The Water Quality programs may also submit blind PT samples for other parameters, as needed.

Reports are sent to all participating laboratories after the study is complete. Laboratories are then required to respond in writing within 30 days describing any corrective actions performed to correct deficiencies discovered during the PE audit. Follow-up audits may be conducted if a persistent problem is noted.

The MPCA evaluates laboratory analytical proficiency of all major and certain other NPDES permittees and/or their contract laboratories that generate analytical data for discharge monitoring report (DMR) submittals to the MPCA in accordance with the conditions of the NPDES permit. Of the more than 1,600 NPDES permittees only 56 have an in–house laboratory. A ‘major’ permittee is a WWTF that has the capacity to discharge 1 M gpd or an industrial facility engaged in a specific business activity such as electricity generation, mining, petroleum refining, or chemical manufacture.

Participating laboratories obtain proficiency test (PT) samples from accredited PT Providers for this study. Reports of the laboratories’ analytical performance are sent to MPCA. A permittee that receives a Not Acceptable evaluation for a parameter as a condition of its permit and for which a discharge limit has been established must participate in the remedial phase of the study by reanalyzing the parameter.

Required participants must submit to the MPCA QAC a written explanation of the possible cause(s) of the Not Acceptable analytical result and initiate corrective actions. The permittee need not analyze permit parameters that are in Monitor Only status. Some facilities participate in this study on a voluntary basis. These facilities need not reanalyze any parameters for which a Not Acceptable evaluation is received. The Water Quality program QAC tracks DMR-QA Study results to ensure that all parameters that are part of the study and for which permit limits have been established have been successfully analyzed. The QAC then

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summarizes the results of NPDES DMR-QA performance and discusses the findings with the Environmental Data Quality Supervisor and Manager as appropriate. If major issues are found, these issues would be documented in a letter of findings sent through the EDQ Supervisor to the Water Program Manager..

Laboratory data submitted to the MPCA must meet specific quality standards and is assessed according to its intended use. At a minimum, laboratory data submitted to MPCA must contain the following:

name of laboratory performing the work

date(s) of sample receipt, extraction, digestion, and analysis

identification of analytical method used

analytical method reporting limits (RL)

QA documentation

analyte concentration units used (e.g., mg/L)

project and MPCA contact names

data transfer chain of custody

narrative describing QA measures, variances, and any unusual circumstances

Note MPCA is currently building an electronic data deliverable for the water database system (EQuIS) which will outline required information to be received from a laboratory and how the information will be submitted to MPCA for electronic data storage. This EDD is currently being reviewed and built as the QMP is being reviewed by EPA. Further information on the EDD will be forthcoming with an anticipated completion date in early 2013.

9.7. Product and Service Evaluations

Product and Service evaluations may include:

Assessment of documents and policies published by the MPCA (also see Section 2.6).

Site actions overseen by the MPCA (also see Section 9.10).

Laboratory services performed for the MCPA (also see Section 0).

Secondary data: site or laboratory information collected for another party then submitted to the MPCA (also see Section 0).

Products purchased by the MPCA (also see Section 4).

These evaluations are performed by staff with the appropriate expertise. For example, a sampling expert, e.g., a Superfund on–site inspector, audits sampling activities, data, and records. The experts are assigned based upon a discussion with management of the best individual to assist in an assessment or as assigned by their site work. A sampling expert is typically an agency staff person with considerable training, expertise, and experience conducting and overseeing environmental sampling activities and training agency staff in the protocols appropriate for the medium being assessed. The QAC may audit contract laboratory data and analytical methods. The QAC may audit contract laboratory data and analytical methods. Following the audit, the auditor meets with the laboratory manager, consultant, or responsible party to review audit findings and any required corrective actions. The auditor then sends a copy of the audit report to the affected party, which must correct any deficiencies noted within 30 days. The MDH, which is the laboratory accreditation authority in Minnesota, is informed of major deficiencies noted during an audit.

Often required service reviews of products or purchased services are contained within the contract for the service or product let by the State through the Department Of Administration (currently named MMB). This information is standard language within contracts ensuring quality of services or products purchased by the State of Minnesota.

A chart indicating the programs audited by QACs may be found in QMP in Table 3. MPCA Quality Assurance Coordinator Staff, Environmental Data Quality Manager 0. Sites involved in multi–media activities may


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receive oversight by a QAC from each medium. The QACs coordinate on–site responsibilities to ensure QA oversight of all phases of the project.

9.8. Peer and Technical Review

The MPCA develops many technical documents for publication. Staff with relevant expertise reviews the information for accuracy. External stakeholders and customers also review the proposed article or policy and submit comments. After revisions are made the document is submitted to management for review and comment, final approval, and signature. The document is then distributed to affected and other interested parties. Typically, the technical document is then posted on the MPCA website.

Through MPCA’s partnership with stakeholders, Section Managers and Unit Supervisors coordinate with external agencies and groups to determine the best methods of remediation, pollution abatement, and pollution prevention. The State has formal requirements for adoption of rule which requires public comment prior to issuance. MPCA normally requests staff and public input on policy effecting programs ensuring unforeseen effects are not felt by the community involved.

9.9. Data Evaluation

The program– or project–level Project Manager is ultimately responsible for ensuring that data generated by or submitted to the MPCA is appropriate for its intended use. This includes scientific study design, QA planning, timely and accurate data entry, QA document development, and data quality activities among field, laboratory, and data assessment staff. Upon request, QACs provide assistance in reviewing data generated for a site. The evaluation technique and method is defined within the project QAPP or other program documentation. As a rule, the project manager on a site or a program manager will be responsible for data evaluation. When questions arise about laboratory data or field measurements, quality assurance coordinators are often contacted for assistance in interpretation and review of data.

Field data and field reports submitted to the MPCA are reviewed for quality by appropriate technical staff, such as a hydrologist review of a groundwater flow and contamination plume report. Although such submittals are typically reviewed by MPCA technical staff, MPCA may contract an outside consultant to perform these tasks by executing, for example, a Superfund multi-site contract. MPCA staff provides consultant, oversight and solicit on-site evaluations and recommendations.

The site or program DQO defines the level of data validation required, which in turn defines the level of data quality assessment (DQA) required. Data may be qualitative or quantitative. For example, statewide monitoring data for trend analysis is qualitative in nature. Although qualitative data must meet quality standards, they are not as rigorous as those for quantitative data.

The MPCA policy defines minimum quality requirements applicable to all programs. For example, all laboratories performing work for an MPCA-administered site or program must be certified by MDH or other approved registration or certification authority as approved by the State. This requirement helps ensure a basic level of laboratory QA. Further assurance may be obtained through laboratory performance and data audits.

The DQA begins with an assessment of the project DQO and a determination if the stated data use objectives are being met. Conclusions drawn from poor quality data may be erroneous and may result in bad decisions and policies. Proper implementation of the DQO process helps prevent erroneous conclusions and bad decisions and policies. Use of the DQO process ensures development of a plan for representative sampling, accurate analysis, and data assessment. Assessed data that meets DQO quality requirements and stated objectives is validated. Data assessment involves the following:

DQO review to ensure stated quality objectives are met


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sampling design assessment to ensure it is complete

statistical evaluation of the data

verification that conclusions drawn are valid

Laboratory Data Submittal Requirements

Laboratory data submitted to the MPCA must meet specific quality standards and is assessed according to its intended use. At a minimum, laboratory data submitted to MPCA must contain the following:

name of laboratory performing the work

date(s) of sample receipt, extraction, digestion, and analysis

identification of analytical method used

analytical method reporting limits (RL)

QA documentation

analyte concentration units used (e.g., mg/L)

project and MPCA contact names

data transfer chain of custody

narrative describing QA measures, variances, and any unusual circumstances

The MPCA is currently building an electronic data deliverable for the water database system (EQuIS) which will outline required information to be received from a laboratory and how the information will be submitted to MPCA for electronic data storage. This EDD is currently being reviewed and built as the QMP is being reviewed by EPA. Further information on the EDD will be forthcoming with an anticipated completion date early 2013.

Field data and field reports submitted to the MPCA are reviewed for quality by appropriate technical staff, such as a hydrogeologists review of a ground water flow and contamination plume report. Although such submittals are typically reviewed by MPCA technical staff, MPCA may contract an outside consultant to perform these tasks by executing, for example, a Superfund multi–site contract. MPCA staff provides consultant oversight but solicit on–site evaluations and recommendations.

9.10. Site Assessments

A site assessment is based upon an objective set of standards such as ASTM E1527–05, Standard Practice for Environmental Site Assessments; Phase I Environmental Site Assessment Process or ASTM 1903–11, Standard Practice for Environmental Site Assessments; Phase II Environmental Site Assessment Process, and is conducted before work may begin on a project or at a site. It may be done internally or externally. An internal assessment is conducted by a MPCA assessor or auditor or one contracted by MPCA to review or audit a specific site, program, or project. MPCA internal assessments include management review, peer evaluation, and technical review. An external assessment is one typically conducted by EPA, the State Legislature, a private organization, or another agency.

9.11. Reporting

All deficiencies noted in an MPCA assessment are documented. Audits or reviews as appropriate are distributed to the proper level of management for review depending on the scope of the review. The manager and project staff will provide verification of findings and corrective actions as required to meet the project DQOs. Depending on the required corrective actions, the program or section manager or the Environmental Data Quality Supervisor may be tasked to track and document the corrective actions in a program or section. For example, if deficiencies are noted in a water program such as NPDES, the QAC and project staff recommends the required corrective actions, document the methods to be used, and submit


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the recommendations to the Unit Supervisor and Section Manager. The Section Manager discusses the recommended corrective actions with the Division Director. The Section Manager and Unit Supervisor review the recommendations and develop a method for staff to implement the corrective actions. The QAC and project staff track the corrective actions and reports the progress to the Unit Supervisor and Section Manager. The Division Director makes the final determination that the deficiencies have been adequately addressed. The QAC and Section Manager keep documentation of the corrective actions taken. Major site corrective actions conducted by a consultant require agency approval to ensure preservation of DQO integrity. All corrective actions are documented by the consultant and MPCA (see Section 5.0) and are detailed in the site or MPCA program QAPrP.

10. Quality Improvement

10.1. Background

Since 2003, the MPCA has been progressively focused on systematically reviewing, improving, and designing more efficient and effective processes. The use of continuous improvement (CI) tools, such as Six Sigma and Lean, provides for a structured method to: assess our processes, gather customer input, collect and utilize data, analyzing current problems, and improving ways to accomplish our work. The MPCA is publicly funded and expected to provide efficient and effective quality programs. One of the goals of the Agency’s Strategic Plan directly addresses continuous improvement at the agency. It specifically reads, “Achieve excellence through application of appropriate tools and best practices.” Since programs are delivered through processes, staff must understand the processes and make them as efficient and effective as possible. To provide the best environmental protection and improvement, the agency must constantly review and improve key processes, because stakeholders require new approaches, standards change, and resources are limited. Also, with the changing environmental landscape and the large volume of emerging issues, it is important to use CI tools for effectively designing new processes and redesign existing processes. It is, therefore, critical to have a thriving culture of CI at the agency. The Governor’s Office in Minnesota is heavily involved in CI and continues to promote CI activities through awards and sharing of information across the State.

Continuous Quality Improvement Assessment Conflict Resolution

A continuous quality improvement assessment that recommends change may create an atmosphere conducive to a dispute if the assessor and the assessed disagree on the nature, scope, or consequences (among others) of the change. Bringing the dispute to a successful conclusion agreeable to all parties involved may require considerable negotiating skill, tact, and patience. This dynamic may result whether the assessment is within, between, or among organizations. Based upon experience derived from myriad disputes and conflicts that have arisen during the life of the agency, MPCA management strongly prefers and recommends use of one of two conflict resolution approaches.

The Cooperation Approach

This approach is characterized by an active concern for both pro–social and pro–self behavior and is typically used when one has an elevated interest in one’s own outcome as well as in the outcome of others. Cooperators collaborate with others in an effort to find an amicable solution that satisfies all parties involved in the conflict. This conflict resolution style tends to be highly assertive and highly empathetic at the same time. By seeing conflict as a creative opportunity, collaborators willingly invest time and resources into finding a “win–win” solution. According to the conflict resolution literature, a cooperative conflict resolution style is recommended above all others (Sternberg & Dobson, 1987; Jarboe & Witteman, 1996).


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The Conciliation Approach

The conciliation or “compromising” conflict resolution style is typical of individuals who possess an intermediate–level of concern for both personal and others’ outcomes. Compromisers value fairness and, in doing so, anticipate mutual give–and–take interactions. By accepting some demands put forth by others, compromisers believe such agreement will encourage others to meet half–way, thus promoting conflict resolution (van de Vliert & Euwema, 1994). This style is an extension of both the “yielding” and the “cooperative” strategies.

10.2. Continuous Quality Improvement Process

The MPCA Deputy Commissioner is responsible for quality implementation and oversees the management team that mandates the quality improvements. The MPCA QA staff typically monitors analytical quality issues by conducting data and project reviews. Agency- or program-wide non-analytical issues are typically identified by legislative audit, stakeholder, or public comment.

The MPCA manages quality improvement though several mechanisms. The two methodologies used for high level formal improvement projects are Lean and Six Sigma. Daily work level quality improvements are done in several ways; some formal and some not, depending on the scope of the improvement.

From the Governor’s office down to the state agencies, Continuous Improvement is being woven into the fabric of the way we do our work. This training provides management staff with the knowledge and the tools to achieve meaningful change thoughtfully and effectively.

The Continuous Improvement (CI) for Leaders training reviews agency–wide improvement projects. The CI Deployment Plan may be found at: http://intranet.pca.state.mn.us/index.php/servicestraining/21–servicestraining/206–continuous–improvement–for–leaders.

Program process documentation and improvement projects are found in an access database internal to the MPCA located at: X:\Agency_Files\Process Documentation\CIProjectPortfolio.accdb within the Agencies internal drives.

10.3. Six Sigma/Enterprise Lean

Six Sigma

To address broad agency-wide or cross-program challenges as efficiently and effectively as possible, the Six-Sigma process was implemented. It may be characterized as follows:

It is a rigorous, statistically-based problem-framing and problem-solving method.

It is a comprehensive systems improvement approach to serving agency customers and reducing waste.

It is a careful application of the scientific method to agency process management.

It is a means of transforming key agency processes to deliver exceptional performance.

It is a means of transforming the agency and its leadership to achieve maximum agency effectiveness.

Figure 11. Six Sigma DMAIC diagram

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Six Sigma Project methods used by MPCA include:

Do It

Rapid Action

Standardization

Discovery

Design (DMADV); and

Improvement (DMAIC)

The Six-Sigma process has six basic themes:

Genuine customer focus.

A management style that is data-driven and fact-driven.

Emphasis on process focus, process management, and process improvement.

A proactive managerial style.

Elimination of staff boundaries and emphasis on staff interaction.

A drive for perfection with tolerance for failure.

More information on the MPCA Six Sigma process may be found here: http://intranet.pca.state.mn.us/index.php/component/content/article/73–agency–operations/management–teams–and–media–forums/425–continuous–improvement–management–team.

Enterprise Lean

Enterprise LEAN is characterized as:

A time-tested set of tools.

An organizational desire to reduce waste and defects within systems and processes.

By engaging staff.

Productivity, quality, staff morale and customer service improvements.

Enterprise LEAN focuses on continuous process improvement. It engages those who work in the process to identify and implement process improvements. Lean has a strong focus on process efficiency, accountability and a bias for action. Lean methods used by MPCA include:

7 Wastes

5S

Standard Work

Kaizen Events

More information on Enterprise LEAN, a process for improving organizational performance in Minnesota state government, may be found here: http://www.lean.state.mn.us/.

10.4. Water Management Continuing Planning Process

The Continual Improvement Process in Water Quality Environmental Management focuses on improving not only the quality of the water resources themselves but also on the natural consequences of the improvements such as fishable and swimmable lakes and streams and enhanced esthetic enjoyment. It also is not limited to small, incremental improvements such as in the Kaizen process but also includes improvements of any scale.



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Effective water resource management requires the planning, organizing, securing, managing, leading, and controlling of water resources to achieve the specific goals of the MPCA Strategic Plan. A water management project is typically a temporary endeavor with a defined beginning and end and is usually constrained by funding, time, and deliverables undertaken to meet specific goals and objectives and to bring about beneficial change or added value. The temporary nature of water quality projects stands in contrast with operations which are repetitive, permanent, or semi–permanent functional activities to produce products or services. In practice, the management of these two systems is often quite different, and as such requires the development of distinct technical skills and management strategies.

The primary challenge of water quality project management is to achieve all of the project goals and objectives within the context of the preconceived constraints of scope, time, quality, and budget. The secondary challenge is to optimize the allocation of necessary inputs and integrate them to meet predefined objectives.

10.5. Program Evaluation

To assess program practices and procedures, management may conduct a routine performance evaluation to verify that program objectives are being met. This is done at the discretion of agency leadership and may include consideration of a program’s life cycle.

The Office of the Legislative Auditor becomes involved only after legislators or key constituents outside the MPCA believe that such a performance evaluation is warranted. Such an audit is more comprehensive than an internal audit. A formal report of the Office’s findings is presented to the Legislature.

10.6. Field Performance Audit

Field performance audits of air monitoring stations, including State/Local Air Monitoring Stations (SLAMS), National Air Monitoring System (NAMS) stations, and industrial sites are conducted as required in 40 CFR § 58, Appendices A and B. The MPCA also participates in the National Performance Audit Program (NPAP) for air monitoring stations as required by 40 CFR § 58, Appendix A. The MPCA also established a QA program for non-criteria air pollutants. This is further discussed in section 9.2 Audits and Surveillance.

10.7. Minnesota Pollution Control Agency Laboratory Quality Control and Data Policy

The MPCA laboratory QC and data policy applies to all laboratory data submitted to the MPCA except where a project-specific approved Quality Assurance Project Plan (QAPP), program guidance or other appropriate systematic planning document takes precedence.

The MPCA laboratory QC and data policy applies to all laboratory data submitted to the MPCA except where a project-specific approved Quality Assurance Project Plan (QAPP), program guidance or other appropriate systematic planning document takes precedence. Failure to follow this Policy may result in data being unusable for MPCA programs, the report rejected, and, if applicable, the invoice contested.

It is the goal of the MPCA’s QC program to ensure that all data submitted to the agency be scientifically valid, defensible, and of known precision and accuracy. The data should be of sufficient known quality to withstand scientific and legal challenge relative to the use for which the data are obtained. The intent is the data is of adequate quality for the program and decisions made based upon the data.

The MPCA requires the use of the most current analytical method final version unless an older version is allowed or required by a program, permit, or QAPP. Laboratories performing SW-846 methods must use the


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most current final versions of these methods. The MPCA will announce when future updates are required to the laboratory community.

When the MPCA adds additional analytes or methods to program requirements, laboratories will be able to wait until their next certification renewal to add newly available analytes or methods to their scope of certification. If the laboratory chooses to expand their capabilities by adding a new method to their analytical services for which certification is required, they must be approved for certification before they can begin accepting client samples. Additional sampling guidance information may be found in Section 8.4. The complete MPCA Laboratory Quality Control and Data Policy document can be found at http://www.pca.state.mn.us/index.php/about-mpca/mpca-overview/agency-strategy/mpca-quality-system.html.

Sampling guidance

Written sampling guidance enables standardization of sampling techniques that helps ensure data quality. The guidance helps ensure a contractor or consultant understands the sampling method and quality assurance that must be an integral part of it. MPCA technical experts write the guidance documents, which are then reviewed by knowledgeable internal and external peers, reviewed by QACs as appropriate, then released to the public. The MPCA may hold public comment and training sessions following release of the guidance document to answer questions and educate data end-users. For example, the Leaking Underground Storage Tank (LUST) factsheets contain guidance for the LUST program. The factsheets may be found on the internet at: http://www.pca.state.mn.us/cleanup/pubs/lustpubs.html.

MPCA Environmental Sampling Guidance and Continual Improvement

At the MPCA the continual improvement process is applied to environmental sampling guidance through use of the plan–do–check–adjust protocol. This is a four–step method that:

Establishes the processes and objectives necessary to obtain high quality environmental data through adherence to sound sampling guidance principles. Sampling completeness and accuracy are fundamental to achieving this objective.

Field staff learn sound field sampling methods through workshops, written sampling protocols (SOPs), mentoring by more experienced field staff, and solicitation of new field staff feedback concerning how to improve the sampling guidance learning process.

To assess the effectiveness of the sampling guidance instruction process, the analyzing laboratory periodically submits to the MPCA QACs a sampling problem/deficiency report that identifies the specific sampling deficiencies noted by laboratory sample receiving staff, the number of such deficiencies, and the sampling staff to which each deficiency is attributed.

This report is shared with the sampling staff to make them aware of the specific deficiencies and to solicit feedback as to how to best remedy the deficiencies.

Based upon the types and numbers of deficiencies identified, relevant SOPs may be updated or expanded and the workshop curriculum modified to better address the deficiencies noted.

The process is an iterative one in the sampling guidance training, sampling activities undertaken, the periodic laboratory problem/deficiency report, and resulting actions taken to improve the sampling guidance process are elements of a loop with each iteration intended to improve the sampling process (and hence the quality of the environmental data obtained) and reduce the number of deficiencies.

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The effectiveness of this process is quantified by the analyzing laboratory problem/deficiency report which includes the percentage of sampling and sampling–related deficiencies noted as compared to the total number of sampling and sampling–related elements during each report timeframe.

The MPCA QACs then compare the sampling deficiency percentages on a continuum to assess whether this iterative process is achieving its intended goal of a continual reduction in sampling and sampling–related deficiencies over time. Such data also serve to inform the QACs as to what constitutes reasonable expectations.

Water Management Continuing Planning Process

The effectiveness of the MPCA water quality management continual improvement process is defined by the extent to which it can be effectively applied to its water programs and projects to achieve these objectives.

Section 303(e) of the Clean Water Act (CWA) requires each state to have a Continuing Planning Process (CPP) document describing the processes and procedures it uses in water quality planning. The objective of the state CPP is to establish a management program and provide a framework for establishing programmatic commitments and goals that will be contained in the EnPPA and other plans prepared pursuant to the Clean Water Act. The purpose of the CPP is to document how the state will make its water quality management decisions. Nine specific processes must be addressed in each state’s CPP. These nine processes are listed below:

1. A process for developing effluent limitations and schedules of compliance at least as stringent as those required by sections 301(b) (1) and (2), 306 and 307, and at least as stringent as any requirements contained in applicable water quality standards in effect under the authority of section 303 of the CWA.

2. A process for incorporating elements of any applicable area-wide waste treatment plans under section 208, and applicable basin plans under section 209 of the CWA.

3. A process for developing Total Maximum Daily Loads (TMDLs) and individual water quality-based effluent limitations for pollutants in accordance with section 303(d) of the CWA and section 40 CFR § 130.7(a).

4. A process for updating and maintaining Water Quality Management Plans, including schedules for revision.

5. A process for assuring acceptable authority for intergovernmental cooperation in the implementation of the state Water Quality Management program.

6. A process for establishing and assuring implementation of new or revised water quality standards, including schedules of compliance, under section 303(c) of the CWA.

7. A process for assuring acceptable controls over the disposition of all residual waste from any water treatment processing.

8. A process for developing an inventory and ranking, in order of priority

9. of needs for construction of waste treatment works required to meet the applicable requirements of sections 301 and 302 of the CWA.

10. A process for determining the priority of permit issuance.

The MPCA’s Water Quality Management Plan includes a separate document just pertaining to Continuing Planning Process. The plan was updated in Dec. of 2010 and can be found at: http://www.pca.state.mn.us/index.php/view-document.html?gid=15647.



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The MPCA’s Water Quality Management Plan includes a separate document just pertaining to Continuing Planning Process. The plan was updated in Dec. of 2010 and may be found at: http://www.pca.state.mn.us/index.php/view–document.html?gid=15647.

References EPA QA/R-2, March 2001, EPA Requirements for Quality Management Plans. QA/R-2 is the policy document containing the specifications and requirements for Quality Management Plans.

EPA QA/R-5, March 2001, EPA Requirements for Quality Assurance Project Plans. QA/R-5 replaces the 1980 document QAMS-005/80. This external policy document establishes the requirements for QA Project Plans prepared for activities conducted by or funded by EPA. It is intended for use by organizations having extramural agreements with EPA.

EPA QA/G-4, February 2006, Guidance for Systematic Planning Using the Data Quality Objectives Process. QA/G-4 provides guidance to help organizations plan, implement, and evaluate the Data Quality Objectives (DQO) process, a systematic planning process for environmental Data generation. It has a focus on environmental decision-making for regulatory and enforcement decisions. The guidance presents a step-by-step description of the DQO process.

EPA QA/G-5, December 2006, Guidance on Quality Assurance Project Plans. QA/G-5 provides guidance to help organizations develop Quality Assurance Project Plans that will meet EPA expectations and requirements. The document provides a linkage between the DQO process and the QAPP. It contains tips, advice, and case studies to help users develop improved QAPPs.

EPA QA/G-7 January 2000 Guidance on Technical Audits and Related Assessments for Environmental Data Operation. provides general guidance for selecting and performing technical audits and related assessments of environmental data operations.

EPA CIO 2106–S–02. Quality Standard for Environmental Data Collection, Production, and Use by Non–EPA (External) Organizations. February 2012.

EPA CIO 2106–G–05 QAPP. Guidance on Quality Assurance Project Plans. January 2012.
