EPA-440/4-84-018
vvEPA
Unit 3d States        Office of Water
Environmental Protection   Regulations and Standards   July 1984
Agency          Washington, DC 20460
Water                           ~~

Planning and Managing

Cooperative
Monitoring  Projects

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 PLANNING   AND    MANAGING
COOPERATIVE   MONITORING
               PROJECTS
                   July 19R4
              Monitoring Branch

    Monitoring and Data Support Division

 Office  of Water  Regulations and standards
      U,S. Environmental Protection ,V-- "
      li'-^-Ion 5,  Library (5PL-16)
      K.-J 3, Daarborn Street, Boom 1670

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                             PREFACE
     The concept of cooperative monitoring is not new.  Coopera-
tive monitoring involves shared efforts by individuals or groups
in assessing water quality conditions and developing local water
quality-based controls.  Cooperative arrangements are encouraged
by the Clean Water Act which states in Section 104(a) that EPA
"in cooperation with other Federal, State, and local agencies,
conduct and promote the coordination and acceleration of...inves-
tigations, .. .surveys, and studies related to the causes, effects,
extent, prevention, reduction, and elimination of [water]  pollu-
tion." Also under Section 104(b), EPA is authorized to "cooperate
with other Federal departments and agencies, State water pollution
control agencies, interstate agencies, other public and private
agencies, institutions, organizations, industries involved and
individuals, in the preparation and conduct of...[the] activities
referred to [above]."

     Cooperative monitoring projects require careful planning and
strong management controls.  This report describes the factors
to be considered in designing and implementing cooperative monit-
oring projects so that specific provisions are made for the collec-
tion and analysis of scientifically valid water quality data and
so that the State water pollution control agencies have final re-
view and approval authority for all projects.

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                              CONTENTS
 CHAPTER                                                     PAGE
      PREFACE

 I .    INTRODUCTION
         Monitoring Objectives
         Role  of  Monitoring  in the Water Quality
           Management  Process
 1 1 .   COOPERATIVE  MONITORING -  OVERVIEW .....................  3

         Approach  ...........................................  3
         Incentives  .........................................  4
         Appl ications  ..................................... >   5

 III.  INSTITUTIONAL  OPTIONS  .................................  8

         Identification  of Needs  ............................  8
         Opportunities for Involvement  ......................  8
         Roles  and Responsibilities  .........................  9
         Meeting Project  Needs  ..............................  9
         Project Agreements  .................................  n

 IV.   FUNDING AND  RESOURCE OPTIONS  ..........................  12

         Direct Funding  .....................................  12
         Indirect  Funding ...................................  13
         Provision of In-Kind Services  ......................  13
         Joint  Funding ......................................  13
         User Fees ..........................................  13
         Combined  Arrangements  ..............................  14

V.    PROJECT IMPLEMENTATION  ................................  15

         Planning  and Management  ............................  15
         Technical Considerations  ...........................  18
         Water Quality Modeling .............................  19
         Quality Assurance/Quality Control  ..................  20

Appendixes

Appendix A - Cooperative Monitoring Case Studies  ...........  A-l

      Lower Fox River, Wisconsin  ............................  A-l
      Middle Wabash River, Indiana ..........................  A-5

Appendix B - Sample Cooperative Monitoring Agreements  ......  B-l

      Illinois EPA with City of Chicago  .....................  B-2
      Fox Valley Water Quality Planning Agency ..............  B-9
      Monmouth County Health Department and New
       Jersey Department of Environmental Protection .......  B-14

Appendix C - Work/Quality Assurance Project Plan Guidance...  C-l
                              - 11 -

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                            CHAPTER I
                           INTRODUCTION
     The purpose of this document is to explain how local par-
ticipation in water quality management may be enhanced while
ensuring that scientifically valid data is collected and used
in decision making.  Local participation through cooperative
monitoring agreements provides a mechanism for increased cooper-
ation among affected and concerned parties in assessing local
water guality and developing water guality-based controls.  This
guidance document focuses on the incentives for these types of
projects and their role in the water quality management process.
The guidance also presents institutional options and consider-
ations for project implementation.


MONITORING OBJECTIVES

     The objective of cooperative monitoring is to support a
particular water quality management activity or process.  These
could be water quality management planning, reviewing water
quality standards, calculating total maximum daily loads/wasteload
allocations for water quality-based decisions, making construction
grant decisions, or determining permit limits for municipal or
industrial dischargers.
ROLE OF MONITORING IN THE WATER QUALITY MANAGEMENT PROCESS

     The Clean Water Act provides federal and State regulatory
agencies with a variety of tools for water quality management to
assure that national water quality goals are achieved.  These
tools include:


     1.   Water Quality Planning and Management (including
          total maximum daily loads/wasteload allocations)

     2.   Water Quality Monitoring

     3.   NPDES Permits and Compliance

     4.   Municipal Treatment Facilities

     5.   Water Quality Standards

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     These tools are dependent upon scientifically sound,  site-
specific water quality data needed to support decision making.
In making decisions on the basis of water quality, the specific
characteristics of the discharges and the receiving water  as
well as the constituents to be regulated must all be considered.
Site-specific data on the aquatic life present, the physical and
chemical characteristics of the water, background conditions,
and low flow conditions are often needed for determining which
controls are most appropriate and for establishing appropriate
water quality-based effluent limitations, i.e., controls
more restrictive than technology-based limits.  Careful consider-
ation of well documented quality assurance/quality control proce-
dures will help ensure that data collected is representative and
scientifically valid.

     This guidance document discusses the appropriate role of
State and local governments, environmental groups, industries,
and others in planning and conducting ambient monitoring with an
emphasis on cooperative monitoring agreements for developing
water quality-based contols.  In light of increased demand for
federal and State resources, data resulting from local cooperative
monitoring efforts could become an essential factor in resolving
questions associated with the development and implementation of
water quality-based controls.

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                            CHAPTER II
                COOPERATIVE MONITORING - OVERVIEW
APPROACH

     Cooperative monitoring is where two or more parties agree
to collect water quality data needed to support water quality
management objectives.  The parties involved may include the
State water quality regulatory agency, ?OR areawide planning
agency, the EPA or other federal agencies, municipal and indus-
trial dischargers, environmental groups, universities, and others
who are affected, concerned, or interested in local water quality
Cooperative monitoring is an approach to achieve maximum use of
limited public monitoring resources by combining them with other
resources in arriving at water quality decisions.

     Cooperative monitoring projects have the same elements as
other monitoring projects.   Data is collected, analyzed, and
reported in accordance with accepted scientific procedures and
the data is interpreted by  the agency responsible for deciding
upon the level of controls  that may be needed.  However,
cooperative monitoring projects have several characteristics
which distinguish them from other monitoring projects:

     1.   Part or all of the cost of the monitoring, data
          analysis, and data interpretation is borne by
          government(s) or  other participants.

     2.   Oversight of data collection, data interpretation,
          and acceptance of the results is the responsibility
          of the State, even though local government and industry
          may participate in the project.  Planning or regulatory
          decisions influenced by the data are also the State's
          responsibility.

     3.   Advanced agreement is obtained by the State regulatory
          agency and all participants on objectives to be achiev-
          ed, roles of each participant, scope and duration of
          the study, quality control procedures, data handling
          systems and procedures, water quality models to be
          used, financing arrangements, and other important
          elements.

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INCENTIVES

     State regulatory agencies have a number of incentives for
encouraging cooperative monitoring agreements.  First, the State
is able to obtain more site-specific and scientifically support-
able data for use in reviewing water quality standards, writing
NPDES permits, making municipal treatment decisions, and develop-
ing wasteload allocations.  Second, decision making will be more
readily accepted by the regulated community and concerned public
if they are part of the process.  Third, State monitoring re-
sources can be conserved and applied to other areas of the State
which could not otherwise be assessed.  An additional benefit of
cooperative monitoring results from the potential reduction in
the number of adjudicatory hearings (and additional water quality
data collection) requested when water quality-based permits are
issued.  This alone could save considerable resources of the
State regulatory agency.

     The incentives for dischargers entering  into cooperative
monitoring projects with State oversight are also significant.
Since the States are obligated to adopt water quality  standards
that include use classifications and numeric criteria, the States
must rely on national criteria documents and other  sources to
establish water quality standards where site-specific data is
lacking.  These national criteria often cannot take  into account
local variations in water quality, aquatic life, background
conditions, etc. which may  influence the application  of the
numeric criteria.  As a result, national numeric criteria may be
more stringent  than necessary  to protect uses on a  specific re-
ceiving water.  Consequently,  controls  imposed by the  State may
be more stringent  than are  actually necessary.

     Local governments, environmental groups, and interested
citizens benefit from participating in  these  efforts  by gaining
improved water  quality and  the opportunity to contribute assis-
tance  and/or  scientific/technical expertise.

     Local universities and other learning  institutions may also
benefit by participating  in a  local cooperative monitoring effort.
Valuable experience in water quality management as  well as an
appreciation  of all participants' needs can  be obtained.   In
addition to active  involvement with local governments,  universities
can  benefit by  providing  real,  "hands-on" assistance in the  field,
in  the laboratory,  and in data processing/data analysis.

     Adjustments  in numeric criteria  or water quality-based
effluent  limits to reflect  site-specific conditions offer  the
possibility of  substantial  savings  in  capital and  operating  costs
for  municipal  and  industrial  dischargers.   Site-specific data
allow  managerial  personnel  to assure  elected and  corporate
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officials  that the  investments made for pollution control are done
on the most cost effective and scientifically supportable basis
to achieve the desired water quality.


APPLICATIONS

     In order to provide a perspective on the different applica-
tions of cooperative monitoring, a distinction is made between
short term (relatively low level) cooperative monitoring efforts,
and longer term (more intensive and possibly more expensive)
cooperative monitoring projects.  Short term cooperative monitor-
ing arrangements are generally aimed at filling data gaps to
establish effluent  limits for permits in a relatively simple,
single discharger situation.  This could be the setting of efflu-
ent limits for a municipal treatment facility or for determining
the level of treatment needed for a new facility.  The short term
cooperative monitoring project is usually characterized by:

     1.   Simplified institutional arrangements probably involving
          only a single discharger and the State agency.

     2.   Limited objectives involving immediate determination of
          mixing zones, presence or absence of certain species of
          aquatic life, immediate measurement of the impact of
          existing  treatment facilities on water quality or biota,
          or other  information necessary to determine effluent
          limits for municipal treatment decisions or for revis-
          ing permits.  Data is necessary for augmentation,
          clarification,  or refinement of decisions.

     3.   Short duration  ranging from one week to three months.

     4.   Relatively limited resource needs in terms of staffing,
          analysis,  interpretation, and reporting.

     5.   Use of definitive quality assurance project plans.


     Long term cooperative monitoring arrangements may involve
data collection for one of (or a combination of)  the following
object ives:

     1.   Establishing appropriate water quality standards,
          including use classifications and numeric criteria,
          either through  an initial review process or a water
          quality standards update.

     2.   Developing appropriate wasteload allocations for complex
          situations and/or multiple dischargers.
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     3.    Determining  use  attainability.

     4.    Identifying  impacts  of  both  point  and  nonpoint  source
          discharges on  a  stream  segment.

     5.    Developing information  regarding  the economics  of
          implementing various levels  of  treatment.

     6.    Follow-on monitoring for determining effectiveness of
          control levels specified in  NPDES  permits.

     7.    Resolving interstate water quality issues  which may
          affect wasteload allocations,  permit limits,  or water
          quality standards.


     The long term cooperative monitoring project is usually
characterized by:

     1.    Complex institutional arrangements involving  more than
          one discharger,  the  State regulatory agency,  and other
          concerned,  interested,  or affected parties.

     2.    A detailed  agreement delineating roles, responsibilities,
          purposes, financial  arrangements,  duration of the
          project, etc.

     3.    Significant  environmental impact possible as  a result
          of the study.

     4.    Longer duration, usually three months  to a year  (although
          this depends on the  purpose).

     5.    Multiple sampling sites for several parameters including
          physical, chemical,  and biological data.

     6.    Use of data in any one of a number of  water quality
          management activities  (standards decisions, permitting
          decisions,  wasteload allocations, point and nonpoint
          source assessments,  economic benefits, follow-on monit-
          oring, resolution of interstate issues, etc.).

     7.   More extensive resource requirements.

     8.   Use of definitive quality assurance project plans.


     Cooperative monitoring agreements are not appropriate  in all
situations  requiring monitoring.  In  the case where  a short  term
project  involves small  dischargers, the States may have  to assume
the  burden  for monitoring and  application of monitoring  data and
use  State resources to  meet these needs.  Where  local funding is

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arranged, small dischargers may not be able to provide resources
equal to those of larger dischargers.  Since they are, or may be,
affected by the outcome, they may choose to provide resources-in-
kind or participate in an advisory or other capacity.
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                           CHAPTER III
                      INSTITUTIONAL OPTIONS
IDENTIFICATION OF NEEDS

     The need for local water quality data may be identified by
persons concerned or involved in the water quality management
process including the EPA, States, affected dischargers, environ-
mental groups, water users, and the public.  Several considera-
tions may influence the decision to seek additional site-specific
information through a cooperative monitoring agreement.  Some of
these are:

     1.   Available data is not adequate in terms of frequency,
          duration, location, or constituents sampled.

     2.   The potential environmental consequences of the deci-
          sion in terms of expenditures for pollution control or
          impacts on the environment are significant.
     3.   The complexity of the situation (number of discharge
          impacted, hydrology, nonpoint sources, biota, etc.)
          warrflnfs adriihinnal  data collection.
OPPORTUNITIES FOR INVOLVEMENT

     Once the need for additional water quality data has been
identified, the next step is to decide who should be involved in
a cooperative monitoring project.  This can be resolved by con-
sidering the following:

     1.   Who has responsibility for decision making?
     2.   Who is affected by the decision?
     3.   Who is interested in the decision?

     The responsibility for decision making, whether for municipal
treatment (new facility or advanced treatment), revised NPDES
permit limits, or for nonpoint source controls (Best Management
Practices) rests with the State or EPA if authority has not been
delegated to the State.  EPA, however, maintains oversight
responsibility.  Others having responsibilities in the water
quality management process may include the regional areawide water
quality management planning agency and interstate commissions.

     In many cases the parties most directly affected by a water
quality management decision will be municipal and industrial dis-
chargers who are discharging into a particular water body.  They
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 also have a vital interest in applying the most cost-effec-
 tive method of protecting uses of the stream to which they are
 discharging, as well as the impacts on downstream segments.  It
 is important to identify public interest groups who are parti-
 cularly interested in the control decisions.  Interested parties
 may include recreational groups,  water users groups, environmental
 groups, sportsman associations, and downstream interests.
 State water rights laws may also need to be considered in  deter-
 mining the potential interested parties.  Involvement of public
 interest groups in the project can provide a valuable source of
 information and may provide a broader perspective to the project
 than would otherwise be the case.  It facilitates communication
 and acceptability of results upon completion to have various
 interest groups participating in  the project,  rather than
 simply being informed of the results at the end of the project.


 ROLES AND RESPONSIBILITIES

      Institutional options that define  the roles and responsi-
 bilities for cooperative monitoring projects should be explored
 to support the  project's objectives and needs.   No one set  of
 institutional arrangements will satisfy all roles in the water
 quality management process.   The  institutional  options are  deter-
 mined from who  is  responsible,  affected,  and/or interested.
 Specific considerations  include:

      1.    What  is  the  objective?
      2.    What  needs  to  be done?
      3.    Who has  expertise?
      4.    Who has  data?


      Linkages need  to  be  established  between what  needs  to  be
 done  and  the identified  participants  in  the  project.   The scope
 of  the  study may vary  from simple,  one-time  analyses  needed  to
 support  a  permit or construction  grant  application  to  multi-year
 studies.   Once  the  objectives have  been defined,  the  challenge  is
 to  coordinate needs with  all participants.


MEETING PROJECT NEEDS

     The level of  involvement in  cooperative monitoring projects
will depend upon the complexity, potential  impacts, and possible
consequences of the decision.  The simplest situation  involving
only the State and a discharger could be the refinement of a
specific effluent limitation.  The most complex situation could
be the potential change of a designated use or the implementation
of water quality-based effluent limits for multiple dischargers.
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In complex situations, these responsibilities should be clearly
described in a written agreement which is approved by all
participants .

     Project Management - Lead responsibilities for management
                     tr6J any or all of the participants.  These
     can include:

          1.   The State water pollution control agency.

          2.   The principal affected discharger.

          3.   The area-wide planning agency.

          4.   A designated lead agency such as U.S.G.S..

          5.   A consultant.

          6.   A committee of those who have responsibilities or
               are involved and/or affected.

          7.   A management subcommittee.
          Regardless of how project management responsibilities
     are assigned, a qualified individual or individuals must
     be made responsible for identifying the specific needs,
     scheduling, resource management, reviewing interim data,
     reporting to lead agencies and involved parties, quality
     assurance and quality control procedures, and overall
     program coordination.
     Water Quality Study Design - The water quality study design
     ?TeJrfnJes~tnJe~anaiyc:tcai^cS'o'l to be used (e.g., mass balance
     or mathematical model), the physical, chemical, and biological
     constituents to be assessed, frequency of monitoring, location
     of monitoring stations, collection of discharge (effluent)
     data, monitoring of nonpoint sources, and hydrologic analyses.

          A water quality study might involve hydrolog ists ,
     engineers, biologists, statisticians, chemists, and other
     technical specialists with adequate technical backgrounds to
     design the study to meet the project objectives and to assure
     that integrity of the data base is unquestionable.  This  is
     particularly important where a mathematical model is being
     used to predict water quality and the study design must in-
     corporate data needs at specific sites to calibrate the model.
     Study design should involve State agencies, since the results
     of the study must ultimately be interpreted by them.  Also,
     the project design should be approved by the project manager
     and the State water pollution control agency.  A quality
     assurance project plan should be prepared during this phase
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     and  it should be approved by the project manager
     and  State water pollution control agency.

     Project Implementation - The implementation phase  involves
     the  actual collection of water, sediment, or tissue samples,
     the  storage and transportation of samples, laboratory analysis,
     and  data generation and reporting.  Individual assignments
     may  be given to State agencies, technical and laboratory
     staffs of affected dischargers, State or federal agencies,
     and/or contractors (including local universities and environ-
     mental groups) and others specified in the agreement.  The
     project manager's responsibility in the implementation phase
     includes assurance that data is being collected in a timely
     manner, that it is being collected according to the study
     design, that samples are being processed according to speci-
     fied procedures, and that the quality assurance plan is
     being followed.


     Data Review and Interpretation of Results - Review and
     interpretation of datais both a technical and managerial
     function.  Ultimately, the State water pollution control
     agency will have to review and evaluate the data as well as
     any  conclusions drawn from the data by the project manager,
     areawide planning agency, or management committee.  Within
     the  process of reviewing and evaluating data throughout the
     study period, there may be varied interpretations among
     technical personnel.   However, if proper study design and
     quality assurance procedures have been used in data collection,
     differences in interpretation will, in many cases, be
     minimized.  Where differences of interpretation may occur,
     quality control procedures should assure that the integrity
     and objectivity of the data base is not questionable.


PROJECT AGREEMENTS

     Agreements regarding cooperative monitoring projects may
range from informal agreements to collect and evaluate
additional data to formal  written agreements involving two or
more parties.   A memorandum of understanding signed by various
parties may suffice as an informal agreement.  For both simple
and complex projects, all  participants should be encouraged to
agree in advance and in writing on all phases of the study.

     The type  of agreement used should depend upon the complexity
of the project, the number of parties involved, and the individ-
ual project roles and responsibilities.   In complex situations
involving the  State, municipal and industrial dischargers,
public interest groups,  contractors,  and consultants,  a formal
written agreement should be developed to establish and assure
understanding  of the project's objectives as well  as the roles
and responsibilities for all  involved parties.   Sample agreements
from actual cooperative  projects are  found in Appendix B.

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                            CHAPTER IV
                   FUNDING AND RESOURCE OPTIONS


     There are several options for funding cooperative monitoring
projects.  Municipal and industrial dischargers may elect to
fund the project directly or provide other resources, such as
staffing or in-kind services for sample collection, laboratory
analyses, data reporting, and program management.  These contri-
butions may be provided by any agency or party involved in the
study.

     Funding options for a specific study should be arrived at
by consensus among all the participants.  The variety of funding
options  (each of which are discussed below) include:

     1.   Direct funding by dischargers
     2.   Indirect funding by dischargers
     3.   provision of in-kind services by parties involved
     4.   Joint funding
     5.   User fees
     6.   Combined Arrangements


     Regardless of  the  funding mechanism used,  it  should be  noted
that final  interpretation of  data  and  translating  this  data  into
specific controls  (including  permit  limits) remains  the responsi-
bility  of the State.   It  is also  the State's  responsibility  to
assure  that QA/QC  procedures  are  established  and followed  through-
out  the course of  study  and that  precision, accuracy,  completeness,
comparability,  and representativeness  of  data are  known and  docu-
mented.
 DIRECT FUNDING

      Under the direct funding option the discharger (or dis-
 chargers)  would directly fund the cost of data collection.   This
 could include contracts with laboratories, consultants, State
 agencies,  or federal  agencies for direct provision of services.
 in the case of multiple dischargers, funding could be pro-rated
 based on any number of factors (e.g., financial ability, flow,
 even split, etc.)  which would be determined by the project manager
 and included in the written agreement.  Collected data would be
 reported to the discharger or the lead agency in accordance with
 the terms of the formal or informal agreement which includes
 provisions for QA/QC, and to the State agency for review and final
 decision.
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 INDIRECT FUNDING

      Under the indirect funding arrangement,  the dischargers
 would provide  funding  to the  lead  agency (the State,  areawide
 planning agency or other agency) and the lead agency  would arrange
 for and  contract with  consultants  or other  agencies to provide
 the services  to meet project  needs.


 PROVISION OF  IN-KIND SERVICES

      Provision of in-kind services by dischargers, State
 agencies,  federal agencies  or areawide planning  agencies  could
 be  a fundamental element of practically any kind of cooperative
 monitoring project whether  it is discharger direct funded,  dis-
 charger  indirect funded,  or other  arrangement.   Dischargers,
 State  agencies,  areawide  planning  agencies, universities,  and
 some environmental groups often have capable  staff which  may  pro-
 vide some  of the needs  for  data collection  or analysis.   This may
 include  management committee  participation, project management,
 design of  the  monitoring  study,  water quality sampling, laboratory
 analysis,  and  analysis  and  reporting of data.


 JOINT  FUNDING

     Given the responsibilities of those  involved in  the  water
 quality  management  process, joint  funding of cooperative monitor-
 ing  projects may be appropriate.   Under this arrangement,  States
 might provide  total or partial  funding  to local  agencies or dis-
 chargers  for them to obtain data needed by  the State.  This same
 arrangement could  also be applied  to  the areawide planning
 agency.  Joint funding arrangements  could substantially augment
 the  resources  provided by municipal  and  industrial dischargers
 and  enable  additional study detail in  key areas  of concern.


 USER FEES

     The States may consider  levying  fees on all permitted dis-
 chargers that  are related to  the expense of developing permit
 limits and monitoring for compliance under the NPDES permit
 program.  Under  the user fee  approach,  a portion of the fees
 collected  by the state from a discharger would be allocated to
 areas where data  is required  for developing water quality stan-
 dards, total maximum daily loads, wasteload allocations, and
 water quality-based effluent limits on a priority basis within
 the state.  The State would then use these funds to finance all
or part of the cooperative monitoring project.  The user fees
 would provide  the revenue source for conducting these analyses.
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COMBINED ARRANGEMENTS

     Any combination of the described funding arrangements could
work in a given situation.  The objective is to find an
approach which:

     1.   Meets the needs of the cooperative monitoring
          project.

     2.   Is within the budgetary constraints of the
          participants.

     3.   Reflects the environmental and financial stakes
          involved.

     4.   Meets the regulatory requirements of the water quality
          management process.

     5.   Addresses the concerns of the public and water user
          groups.
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                            CHAPTER V
                      PROJECT IMPLEMENTATION
     Elements of project implementation to be considered are
planning and management and technical considerations.  Planning
and management considerations assure that all parties — the
regulatory agency, the regulated community, affected parties
and public interest groups — are working towards achieving
the established goals and that the appropriate quality control
features are being addressed.  Technical considerations assure
that cooperative monitoring projects provide a scientific
approach to determine cause/effect relationships and that State
approved procedures are followed.
PLANNING AND MANAGEMENT

     The level of effort associated with a project involving
several participants will be highly dependent upon the complexity
of the situation and the water quality management process or
function supported:  planning, water quality standards, wasteload
allocations, permits, and municipal treatment decisions.  To help
ensure that the planned goals of the effort are achieved, several
planning and management activities associated with the agreement
must be considered:

     1.   Defining the scope of the project
     2.   Project management and design
     3.   Project implementation
     4.   Data review and interpretation
     5.   Decision making
     6.   Follow-on monitoring


     Project Scope.  The key considerations in scoping a cooper-
     ative monitoring project include:

          1.   Defining the purpose and objectives of the
               project.

          2.   Identifying participants (who is responsible,
               interested, affected; who already has data; who
               has expertise).

          3.   Identifying hydrologic reaches or impact zones to
               be considered.
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     4.    Identifying  the  tributary  area  impacting  the
          hydrologic boundaries  of the  study.

     5.    Determining  what point and nonpoint  sources  will
          be  identified  and characterized as part of the
          study.

     6.    identifying  the  expected output of  the project —
          wasteload allocations, water  quality-based permit
          limits  for specific constituents,  recommended
          water quality  standards, or updated  208 areawide
          management plans.


Project Management and Study Design.  From among the
participants, a project  manager or project coordinator
needs to be identified and a management structure for  the
project must be decided  upon.  This  is  usually a management
committee, an advisory committee, etc.   Management  respon-
sibilities in cooperative monitoring projects include:

     1.   Designing the  study.

     2.   Scheduling activities.

     3.   Developing a quality assurance/quality control
          project plan.

     4.   Defining public  participation  needs.

     5.   Identifying funding and other  resources needed to
          carry out the cooperative project.

     6.   Identifying procedures for data handling and
          management.

     7.   Assuring that project  objectives are met on  a
          timely  basis and within the  resource constraints.


     One  of  the most  important  functions of project manage-
ment is to design the water quality  study.  This is particu-
larly  critical if a mathematical model is being used  to de-
termine wasteload allocations or instream effects  since data
collected will be used  in calibrating  the model.   Consideration
must be given  to  the  following  when designing  a water  quality
study:

     1.    Physical, chemical, and biological  constituents
           (including  stream charactersitics for water  quality
           models) to  be monitored.
                          - 16 -

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      2.    Frequency of monitoring  for each constituent.

      3.    Location of ambient monitoring stations.

      4.    Resource needs  in  terms  of sampling, laboratory
           equipment, analysis, and reporting.

      5.    Collection of water quality data on effluent
           discharges.

      6.    Monitoring of nonpoint sources and background.

      7.    Monitoring of flow and hydrologic conditions.

      8.    Quality assurance procedures

      9.    Safety considerations


Project Implementation.  The project implementation phase
may include the following activities:

      1.    Water quality sampling

      2.    Stream flow measurements

      3.    Laboratory analysis and data reporting

      4.    Biological monitoring (bioassay & biosurvey)

      5.   Historical hydrologic data analysis

      6.   Historical water quality data analysis

      7.   Discharge data analysis

      8.    Implementation of quality assurance/quality control
          plan

      9.   Project coordination

      10.  Public participation

      Responsibilities for all of these activities should be
clearly defined in the development of roles and responsi-
bilities for the project.   The project manager's or management
committee's duties include overseeing all of  these activities
during the implementation phase.


Data Review and Interpretation.   Data review and interpre-
tation should be a continuing process during  the program
implementation period,  particularly if mathematical models
are used to predict instream conditions  as  the  basis for


                         - 17 -

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     wasteload allocations.   It  is  extremely  important  that the
     data  be  reviewed  to  ensure  that  it  is  sufficient to  cali-
     brate the model used.   Review  and evaluation during  the
     program  implementation  phase may indicate  the need for
     additional data or different kinds  of  data.   State water
     pollution control agency personnel  should  be involved  in
     the ongoing process  of  reviewing data,  particularly  where
     the data is to be used  in writing permits,  reviewing or
     revising water quality  standards, and  construction grants.
     All final data should be entered into  EPA's STORET system
     and all  appropriate  water quality data should be reported
     to EPA in STORET  compatible format.


     Decision Making.   Cooperative  monitoring projects  support
     decision making  in the  water quality management process.
     Site-specific data from a well designed monitoring project
     will  support conclusions which are  incorporated into,  or
     influence, a water quality management  decision in  the  areas
     of planning, wasteload  allocations,  water quality  standards
     setting/revisions, permits, or construction grants.


     Follow-on Monitoring.   Follow-on monitoring (monitoring con-
     ducted after controls  are in place to  ensure effluent  limita-
     tations  are effective and that designated uses are being
     restored or maintained) is one way of  providing a  margin of
     safety and assure the validity of water quality management
     decisions.  Follow-on monitoring can provide assurance to
     regulatory agencies  and the public that classified water
     uses are being protected, and  assurances to dischargers
     that water quality-based controls are  reasonable  for the
     use being protected.  Follow-on monitoring projects require
     the same kinds of activities as the initial cooperative
     monitoring project.   Roles and responsibilities have to
     be defined, study plans developed,  data reviewed and inter-
     preted periodcally,  and quality assurance plans developed.
     Follow-on monitoring may or may not be part of a cooperative
     monitoring project.


TECHNICAL CONSIDERATIONS

     A key objective  of cooperative monitoring is to identify
cause and effect relationships among pollution sources  and
conditions which occur in receiving water bodies.  Pollution
sources may include municipal and industrial discharges or  non-
point sources such as  urban  runoff, agricultural return flows,
and runoff from construction areas, timber harvesting  areas,
landfills, etc.  Other factors which may affect receiving waters
include hydrologic conditions, physical conditions  (stream bed
and bank), and habitat characteristics.  The objective  of most
monitoring projects is to provide a scientific basis for relating
pollution sources affecting  receiving waters to observed or
expected conditions.   Participants  in cooperative monitoring

                               -18-

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projects should follow the State's guidance on approaches and
technical procedures.  The State will also have access to EPA
guidance and recommended procedures which can be made available
to cooperative monitoring participants.

     There are a number of techniques and procedures available
for defining causes and effects in water quality.  These include
monitoring of the chemical constituents of receiving waters and
relating these constituents to specific point and nonpoint sources.
Constituents believed to be causing impacts (existing or projected)
should be monitored, as well as other related parameters to assure
that a logical relationship can be defined.

     Flow measurements are commonly recognized as critical since
wasteload allocations, water quality standards, and most water
quality-based permit limitations are related to flow conditions
in the receiving water.  Flow measurements make chemical data
useable in many cases, and provides an invaluable perspective on
the relationship between point and nonpoint dischargers and
their chemical impacts on water quality.

     Biomonitoring of effluents and receiving waters is a useful
tool in defining existing or projected impacts of point and
nonpoint source discharges on biological communities, and for
relating limitations on biological communities to other factors
such as flow, benthic, or bank conditions.  Biological monitoring
may encompass biosurveys in which the occurrence of fish or
benthic life in a stream are quantitatively measured, and sub-
sequently related to pollution levels or habitat characteristics.
Another useful biological monitoring tool is the habitat survey
in which stream bed and bank conditions are identified and factored
into the relationship between the overall characteristics of
the stream and the aquatic communities found in that stream.
Habitat surveys may be a critical element in defining the attain-
ability of aquatic life uses in many cases.

     Another techniaue is the use of bioassays.  Bioassays define
allowable levels of pollutants in specific receiving waters, and
can be carried to a level of sophistication where they are related
to the species which occur in specific receiving waters.   Bioassays
are usually performed on the effluent from a particular discharger
and may be performed in conjunction with biological assessments
of the receiving waters.
WATER QUALITY MODELING

     Mathematical models are frequently used in assessing water
quality and developing water quality-based controls.  Water
quality models simulate the impact of point and non-point source
discharges on the quality of receiving waters,  and they can be
                              - 19 -

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used to predict water quality under a variety of conditions.
Water quality modeling may be done by relatively simple hand
calculations or with sophisticated computer systems.

     The principal advantages of water quality modeling are:

     1.   The impact of future wasteloads can be predicted.

     2.   The sensitivity of the receiving water body to chang-
          ing waste loading or hydrologic conditions can be
          analyzed.

     3.   Critical flow or loading conditions under present and
          future flows can be identified.

     4.   The impact of new sources with respect to existing
          sources can be analyzed.

     5.   The water quality benefits of potential point and non-
          point source controls can be quantified.


     With proper application, water quality modeling provides a
means  of comparative anlaysis of existing and future conditions,
and of  the potential benefits of alternative point  and nonpoint
source  wasteload allocations.  Having identified the necessary
reductions in wasteloads, the ways and means of achieving  those
reductions can be analyzed and the cost of alternative wasteload
allocations  can be considered.
QUALITY ASSURANCE/QUALITY CONTROL

      A fundamental element of  any water  quality data  collection
and analysis effort, and particularly a  cooperative monitoring
project where  several participants  are  involved,  is the  quality
assurance project plan.  A quality  assurance project  plan
establishes  scientifically acceptable procedures  to be used  in
sampling, laboratory analysis,  and  reporting.  Developing  a
plan  which  is  acceptable to  the State and  EPA  at  the  outset  of  a
project and  careful attention  by those  responsible for ensuring
that  QA/QC  procedures are  followed  can  eliminate  much of the
debate surrounding interpretation of data.

      A combined  Work/QA project plan should  describe  the project
and  specify  the  project's  organization  and management responsi-
bilities.   It  should  also  include a thorough description of  the
following specific items:

      1.   Quality Assurance  Officer
      2.   Data Quality Requirements and Assessments
                               -  20  -

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     3.   Sampling Procedures
     4.   Calibration Procedures and Preventive Maintenance
     5.   Documentation, Data Reduction, and Reporting
     6.   Data Validation
     7.   Performance and System Audits
     8.   Corrective Action
     9.   Reports


     These and other elements of a Work/QA Project Plan are
discussed in Appendix C.  If additional information relative to
quality assurance and quality control is needed, the State Quality
Assurance Officer or the EPA Quality Assurance Officer in the EPA
Regional Office may be contacted.
                              - 21 -

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APPENDIXES

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                            APPENDIX A
               COOPERATIVE MONITORING CASE STUDIES


     Local cooperative monitoring projects have been conducted
throughout the nation for various purposes.  Two of these projects
are  included here as case studies to show how State and local
governments worked together with dischargers and others in a
cooperative effort to achieve common goals.

     Selected as cooperative monitoring case studies are the
Lower Fox River, Wisconsin, and the Middle Wabash River, Indiana.


LOWER FOX RIVER, WISCONSIN

     The Lower Fox River from Lake Winnebago to Green Bay,
Wisconsin experienced severe dissolved oxygen depletion problems
during several months of the year.  Discharges from pulp and
paper mills and municipalities in certain areas created major
water quality problems including fish kills.  This 40 mile stretch
of the Lower Fox River also received heavy waste loads from 14
paper mills and six municipalities.  The river has relatively
low flows compared to most other streams receiving mill wastes
and has been extensively dammed for power generation and trans-
portation.

     Concerned with the impact of the discharges on the water
quality of the Lower Fox River and Green Bay, the Wisconsin
Department of Natural Resources (WDNR) used a mathematical sim-
ulation model to determine if Best Practicable Technology and
secondary treatment systems would be adequate to achieve the
desired minimum desolved oxygen standard.  Based on the results
of the study, the WDNR concluded that categorical effluent limit-
ations would not be sufficient to meet the established standard
for recreational use, fish, and other aquatic life in the Lower
Fox River.  The river was described as having one of the ten worst
dissolved oxygen problems in the country.  The WDNR requested that
the Fox Valley Water Quality Planning Agency (FVWQPA)  - designated
under Section 208 of the Clean Water Act to conduct areawide
water quality management planning - develop wasteload allocation
(WLA) and policy recommendations for the Lower Fox River.   The
philosophy of the WDNR was that once it determined the assimilative
capacity of the river, local parties should decide how to manage
or allocate the wasteload among dischargers.
                               A-l

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     As a result of the WLA activity, some of the paper mills
along the Lower Fox and Wisconsin Rivers (WLA's were being develop-
ed for the Wisconsin River at the same time as those for the Lower
Fox) formed a consortum called the Industry Rivers Study Committee
(IRSC).  Initially, the IRSC was organized because the industries
wanted to examine the QUAL III mathematical model used to predict
dissolved oxygen levels.  The IRSC conducted some independent
monitoring, but it also performed monitoring in cooperation with
the local 208 Agency and provided useful comments on the modeling
process.  In addition, the public was actively involved during
all stages of WLA development.  The FVWQPA held several public
meetings to discuss the issues.

     The WDNR and the local 208 Agency independently and in
cooperation with the USGS, IRSC, Green Bay MSD, University of
Wisconsin Sea Grant Program and others, participated in the
monitoring activities.  Parameters measured for QUAL III included
river flow and temperature, headwater biochemical oxygen demand
(BOD), nutrient concentrations, algae concentrations, sunlight
intensity, and BOD loads from each discharger.  Sampling occurred
at five continuous monitoring stations and synoptic surveys were
done during the critical late spring, summer, and early fall
months.

     Most laboratory analyses were conducted by the State Hygiene
Laboratory in Madison, Wiscbnsin.  Additional analyses were
conducted at the University of Wisconsin - Oshkosh, and private
laboratories.  Any incorrect sampling methods were rectified and
U.S. EPA guidance for quality assurance/quality control was
followed.

     During the first two years of the project, federal grants
paid all the costs.  The following three years were funded with
75% Federal, 12 1/2% State and 12 1/2% local monies.  Subsequently,
the WLA effort was financed equally by EPA, WDNR, and the local
area.  Industries have also provided some monitoring funds on a
matching basis with the Fox Valley Agency and local universities.
A summary of resources and responsibilities by participants for
1982-1984 is tabulated on the following page.

     The wasteload allocations developed were for summer low
flows, high river temperatures, and other restrictive conditions.
As  a means to provide the "real time" temperature and flow in-
formation that would be needed to implement variable permits, the
paper mills and municipalities along the Lower Fox River formed
the Lower Fox River Dischargers Association.  The temperature and
flow  information will be obtained daily by the Association and
transmitted to the participating dischargers and the WDNR.
                               A-2

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     The yearly membership dues in the Association provides each
member with the daily readings necessary to meet its permit
requirements.  Since monitoring has not yet started, operating
costs for the Association are not finalized.

     All the parties involved in this unique WLA effort are
satisfied with the results so far.  The dischargers believe the
WLAs evolved through the best and most equitable process possible
The only mill to contest its permit has ceased operation.  The
other dischargers have accepted their effluent limitations.
REFERENCES
     William Elman, Executive Director
     Pox Valley Water Quality Planning Agency
     140 Main Street
     Menasha, WI  54952
     (414)  725-3343

     Dennis Hultgren, President
     Lower  Pox River Dischargers'  Association
     Appleton Papers Incorporated
     Locks  Mill
     Combined Locks, WI  54113

     Dale J. Patterson
     Wisconsin Department of Natural Resources
     P.O. Box 7921
     Madison, WI  53707
     (608)  267-9352
                               A-3

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                                            SUMMARY OF RESOURCES BY PARTICIPANTS
PARTICIPANT

Fox Valley Water Quality Planning
 Agency
Green Bay Metropolitan Sewerage
 District
Industry Rivers Study Committee
RESPONSIBILITIES

Serve on Program Steering Ccmnittee.
Technical Co-ordination and Information
 Transfer through Sub-Ccmmittee of
 Technical Advisory Committee
River Monitoring

Assist in Field Program Cordination
River and Bay Monitoring
Serve on Program Steering Ccranittee
Fund UWM and UWGB During Feb.-Sep.,
 1982
Sediinent Oxygen Demand Field Data
Aerial Photography
Consulting
Serve on Program Steering Conmittee
ESTIMATED CONTRIBUTIONS

$2,800 Cash  (Monitoring)-1982  (ccmmitted)
$30,000  In-Kind  (Staff)-1982  (ccmnitted)
Monitoring Equipment
Up to $100,000 Cash-1982  (comitted)
Up to $100,000 Cash-1983  (expected)

Up to $25,000 In-Kind-1982  (committed)
Up to $25,000 in-Kind-1983  (expected)

Up to $50,000 Cash-1982 (committed)
Up to $50,000 Cash-1983 (expected)
Wisconsin Department of Natural
 Resources
University of Wisconsin (Sea Grant,
 Milwaukee, Green Bay)
Bay Lakes Regional Planning Agency
Model Development
Field Data Collection and Monitoring
Laboratory Analysis of Data
Serve on Program Steering Committee

Chair Program Steering Committee
Field Data Collection and Monitoring
Laboratory Analysis of Data
Adaptation, Calibration, and Verification
 of model
Serve on Program Steering Committee
Serve on Program Steering Committee
Coordinate with other Green Bay Programs
Equipment and Personnel
$50,000 In-Kind-1982  (conmitted)
$50,000 In-Kind-1983  (expected)
Equipment and Personnel
$50,000 In-Kind-1982 (ccranitted)
$50,000 In-Kind-1983 (expected)

$50,000 In-Kind-1982,1983 (Sea Grant-
 requested )
$50,000 In-Kind-1983,1984 (Sea Grant-
 requested )

Up to $5,000 In-Kind-1982 (committed)
                                                                                   TOTAL
                                                                                          400,000 Cash-1982-1984
                                                                                          280,000 In-Kind-1982-1984

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                    MIDDLE  WABASH  RIVER,  INDIANA
      The  Middle Wabash  River extends  approximately  150  river miles
 from  north  of  Lafayette to Merom,  Indiana.  Ten major  industrial
 dischargers, four steam electric generating stations, and six
 municipal wastewater  treatment  facilities are  located along this
 reach of  the River.

      The  Indiana Stream Pollution  Control Board (ISPCB) and the
 industrial  dischargers  along the Middle Wabash River disagreed on
 permit effluent limitations based  on  wasteload allocations.  The
 WLAs  were initially developed from a  mathematical model using
 fixed station monitoring data generated since  1957, and from data
 collected during comprehensive  surveys conducted in 1974 and
 1977.  Both the State and the Mid-Wabash Industrial Consortium
 recognized  the need for updated information on which to base
 wasteload allocations that would be used to draft new NPDES
 permits.  The State and the Consortium agreed  that a third-party
 consultant  should be employed to review all available data,
 identify data gaps, recommend a plan  of study, evaluate and
 calibrate the model, and apply  the model to the river.

     The Mid-Wabash Industrial  Consortium agreed to fund the
 consultant's activities.  The State then formed the Mid-Wabash
 River Technical Committee which included representatives of the
 State of Indiana, the U.S. EPA, the USGS, Purdue University, and
 DePauw University.

     The Technical Committee is open  to industrial, governmental,
 and political concerns and includes representatives from five in-
 dustries, two universities, the Indiana Division of Water poll-
 ution Control,  EPA, USGS, four local governments,  and two environ-
mental consultants.  The Technical Committee organized three
 subcommittees to address specific subject areas,  and to evaluate
 and recommend methods which would be  appropriate for the Middle
Wabash River.   Using the input provided by the subcommittees,
 the Technical Committee developed a work plan provided through
the ISPCB.  The work plan was reviewed and approved by EPA, and
 the survey  was  implemented in the summer of 1981.

     The survey required the participation of a number of organ-
 izations and persons to complete the study tasks.   The tasks and
participants in the survey were as follows:

     o    Intensive sampling and testing of the Middle Wabash
          River and the industrial effluents to determine prescribed
          water characteristics performed by ISPCB,  DePauw and
          Purdue Universities,  and the Public Service  of Indiana
          (PSI).
                               A-5

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     o     Diurnal  dissolved  oxygen  determinations  by  Purdue
          University  from  hourly  stream  samples  collected  and
          preserved  in  the field  by the  intensive  sampling crews.

     o     Primary  productivity  and  respiration measurements
          determined  by ISPCB and DePauw University  using  the
          light  and  dark bottle method.

     o     Determination of ultimate BOD  using  both the inhibited
          and  uninhibited  method  on filtered and unfiltered
          samples  by  Purdue  University.

     o     Proportional  analysis of  major taxonomic groups  of
          phytoplankton by ISPCB.

     o     Determination of benthic  oxygen demand by  ISPCB.

     o     Bottom contour mapping  conducted by  DePauw and Purdue
          Universities  and PSI  to be used for  calibration  of the
          model's  hydraulic component.

     o     Determination of time of  travel and  reaeration rate
          coefficients  by  the USGS  and  ISPCB.


     The field work  has essentially been completed,  but the  model
and the final  wasteload allocations have not been  finalized.  To
date, the Mid-Wabash Industrial Consortium has spent approximately
$280,000; the  USGS approximately  $50,000; and  ISPCB over $120,000
on the  study.

     Quality assurance/quality control  was maintained through the
careful outlining  of procedures prior to the survey, sample
splitting, routine laboratory checks, and continuous communications
between all parties  involved.  Although the final  results of the
study have not been completed,  no major problems have occurred
with the methods employed  or the  quality of the data obtained.
The collected data are currently  being  inputted in the DIURNAL
model.

     From the State's perspective,  this cooperative monitoring
effort has been a success.  The  State believes that through local
cooperation, duplication  of effort can  be largely eliminated and
total combined costs reduced.  The State plans to foster  this
cooperative atmosphere through continued communication with the
industrial group.  Currently,  the  State is planning a toxics
monitoring program for the Middle  Wabash and East Fort White
Rivers.  The ISPCB also anticipates local cooperation with
concerned industries in the  toxics effort.
                                A-6

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Contact
     Mr.  John Winters
     Indiana Stream Pollution Control Board
     1330 West Michigan Street
     Indianapolis, Indiana   46206
     (317) 633-0719
                               A-7

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                            APPENDIX B
             SAMPLE COOPERATIVE MONITORING AGREEMENTS
     The basic foundation to achieving a successful cooperative
monitoring project is a clear understanding by all participants
as to who will be responsible for the variety of activities to be
accomplished.  These responsibilities should be defined in a care-
fully organized work plan with commitments specified in formal or
informal agreements.  To assure the best level of understanding,
written agreements are preferable.

     Several example agreements between various levels of government
and others are included here.  These agreements are included
solely for example purposes and they are not to be considered as
endorsements or recommendations by the EPA.
                               B-l

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ILLINOIS EPA WITH CITY OF CHICAGO
             B-2

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                            MEMORANDUM OF_AGREEMENJ_
                       BETWEEN THE ILLfMOIS"ENVIRONMENTAL
                          PROTECT I ON_AGE.NCY_ (IEPA)_ANJ)
                    THE cirmrri
                                           OF
The purpose of this agreement is to interlink  the City of  Chicago  continuous
ambient water quality monitoring network  with  the State of Illinois  network,
providing both parties access to the network information of mutual concern,
eliminating duplicative monitoring and meeting the following objectives:

1.  Characterize and define trends in the physical, chemical and biological
condition of Lake Michigan.

2.  Establish baselines of water quality.

3.  Provide for a continuing assessment of water pollution control programs.

4.  Identify and quantify new or existing water quality problems or  problem
areas.

5.  Act as a triggering mechanism for intensive surveys or other appropriate
actions.

I.  The I EPA agrees to:

A.  Provide the City of Chicago with water quality data from any portion  of
the state-wide ambient monitoring network if so requested  by the City of
Chicago.  This will be performed to the extent available resources permit.
                               B-3

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Page 2
B.  Enter the data from the IEPA ambinnt monitoring network into the STORE!
system for permanent record and retrieval purposes.  Entry to be made within
90 days beyond the month in which the samples are collected.

C.  Collect and analyze a split sample from each of the designated National
Ambient Water Quality Monitoring Network Stations; parameters to  include  those
 indicated below.

All  laboratory test  results on  these  samples will  be  routinely  submitted  to
 the  City  of Chicago  for comparative record purposes.
 Parameter  Name
STORE! Numbers
 Arsenic
 Cadmium
 Chromium
 Copper
 Mercury
 Lead
 PCBs
 Aldrin
 Oieldrin
 !otal  DO!.
(01002)
(01027)
(01034)
(01042)
(71900)
(01051)
(39516)
(39330)
(39380)
(39327)  (39320)  (39315)  (39310)  (39305)
(39300)
                                 B-4

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Page 3
Chlordane                            (39350)  (39062)  (39065)  (39068)  (39071)
Endrin                               (39390)
Methoxychlor                         (39480)
Hexachlorocycloliexane                (39334)  (39810)
Hexachlorbenzene                     (39700)
Pentachlorphenol                     (39032)

0.  Furnish the Department a copy of the IEPA quality control manual  to serve
as a guide in the audit of the procedures for sampling, transporting, and
analyzing samples.

11.  The City of Chicago Agrees to:

Collect and analyze water column samples from Lake Michigan  in the following
manner:

A.  Samples are to be collected from the locations and frequencies indicated
in Appendix A.
                       (Appendix  is  not attached)
B.  The Lake Michigan monitoring network will consist of 10  (11) stations of
the North Shore Lake Survey,  the 11  stations of the South Shore Lake Survey,
the 23 (33) stations of the James W. Jardine Water Purification Plant Radial
Survey, the 22 (32)  stations  of the South Water Filtration Plant Radial  Survey
and the 14 stations  of the Lake Michigan Open Water Survey.  The locations of
these stations are shown on Appendix A.
                                  B-5

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Page 4
C.  Water column samples are to be analyzed for the following minimum
parameters:
Parameter Mamo
STORE! Number
PH                                  (00400)
Temperature                         (00010)
Conductivity                        (00095)
Dissolved oxygen                    (00300)
Total  suspended solids              (00530)
Total  volatile suspended  solids     (00505)
Turbidity                           (00076)
Total  ammonia nitrogen              (00610)
Total  organic nitrogen              (00625)
Nitrite  - nitrate  nitrogen          (00530)
Chemical oxygen demand              (00335)
Fecal  coliform                      (31616)
Total  coliform                      (31503)
Orthophosphate  (total)               (70507)
Total  phophorus                     (00665)
Chloride                            (00940)
 Sulfate                              (00945)
 Plankton .                           (60050)
 Actinos                              (      )
 Odor threshold                      (00086)
                                    B-6

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Page 5
D.  Perform bottom sediment monitoring in accordance with the Lake Michigan
sediment monitoring program of the City of Chicago.

E.  Perform benthos monitoring in accordance with the Lake Michigan Benthic
monitoring program of the City of Chicago.

F.  Enter the data from the monitoring described in this agreement into the
national STORE! system for permanent record and retrieval purposes; entry to
be made within 90 days beyond the month in which the samples are collected.

Additionally, the City of Chicago will enter all other data collected, such as
more complete parametric coverage, sediment and benthos surveys and other
special studies,  into the national STORET system within the 90 day time
period.

III.  The City of Chicago and IEPA jointly agree to;

A.  Maintain a program of quality control and custody of sample acceptable to
the United  States Environmental  Protection Agency  (USEPA) and the United
States  Geological Survey  (USGS)  with coordination  by the representative
designated  by  IEPA.  A single coordinated quality  control program bringing
together all participants will be a goal of this agreement.

B.  Participate  in a training program  including field and classroom training
to ensure that proper collection procedures are followed.

C.  Cooperate with each other as well  as USEPA and  USGS to  provide a
 laboratory  quality control program.  Such orogram  will be coordinated  by  the
designated  representative of  the IEPA.
                                   B-7

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Page 6
D.  All differences or discrepancies will be negotiated vigorously to a
mutually satisfactory solution.

E.  The effective date of this agreement is October 1, 1977.

F.  If either party to this agreement for any reason wishes to cancel or
modify its involvement, at least ninety (90) days advanced notice to the other
party shall be provided.
date
signed by	
for the City of Chicago
date	
signed by
for the Illinois Environmental Protection Agency
                                  B-8

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FOX VALLEY WATER QUALITY PLANNING AGENCY
                   B-9

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                             INTERAGENCY  AGREEMENT
                                       for
           SUPPLEMENTAL FUNDING OF 1982 RIVER/BAY MONITORING PROJECT
                                    between
                    FOX VALLEY WATER QUALITY PLANNING AGENCY
                                       and
                    GREEN BAY METROPOLITAN SEWERAGE DISTRICT
     This AGREEMENT is made by and between the Green Bay Metropolitan Sewerage
District (hereinafter referred to as "METRO")  and the Fox Valley Water Quality
Planning Agency (hereinafter referred to as "AGENCY") and entered into this 2 y
day of  Jsjjl-fiti  *Hl '.  1982.
     WHEREAS the AGENCY has been designated as an areawide waste treatment manage-
ment planning agency by the U.S. Environment Protection Agency pursuant to Section
208 of the Federal Water Pollution Control Act Amendments of 1972 , (33 U.S.C.
1251 et. seq.) j  and

     WHEREAS the METRO is a Wisconsin municipal corporation organized to perform
regional wastewater treatment services under Wis. Stats. 66.20) and

     WHEREAS the AGENCY has received a grant pursuant to Section 208 of the
Federal Act to do areawide waste treatment management planning within its planning
area and desires to contribute a portion of this grant toward a project known as
the 1982 River/Bay Monitoring Project} and

     WHEREAS METRO is voluntarily functioning as coordinator for the various
federal, state,  and regional and industrial organizations that are voluntarily
contributing personnel, financial, and equipment support towards the said project) and

     WHEREAS the Agency shall be a member of the 1982 River/Bay Monitoring Project
Steering Committee;

     NOW THEREFORE, by and in consideration of the covenants hereinafter expressed,
the AGENCY and the METRO mutually agree as follows :

1. PROJECT - The Project referred to herein is known as the 1982 River/Bay Moni-
   toring Project which consists of voluntary cooperative efforts by numerous
   federal, state, regional, industrial, and consulting engineer organizations to
   establish existing water quality characteristics such as currents, temperatures,
   dissolved oxygen, pH, sediment oxygen demands, and other parameters in the
   Lower Fox  River and waters of Green Bay.

2. COMPENSATION -  (a) The  AGENCY desires to contribute and will contribute the SUB
   of  $2,800.00 to METRO as a contribution toward the costs of completing the
   said project.
    (b) The stated  $2,800.00 will' be paid to METRO and METRO will apply this sum
   to  a separate fund which has been established within the METRO accounting sys-
   tem for purposes of isolating and recording all monetary contributions by
   METRO and  others, including the $2,800.00 from the AGENCY.
    (c)  Disbursements by METRO from this separate fund are for the sole purpose of
    financially supporting  River/Bay Monitoring Project expenses such as hardware,
    salaries,  services, and expendables as are approved by METRO and the other
    contributors.
    (d)  The  $2.800.00 contributed by the AGENCY will be disbursed from the separata
    fund only  for those purposes approved by the  AGENCY prior  to disbursal and as
    shown  on the attached Budget Summary.
                                      B-10

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3. TIME OF PERFORMANCE - The portion of the project supported by the AGENCY is
   scheduled to run from September 1, 1982 to December 30, 1.982.  This Agreement
   will terminate December 30, 1982.

4. METHOD OF PAYMENT - The AGENCY will forward payment of the entire sum of $2,800.00
   to METRO within ten (10) days of execution of this Agreement, to be deposited
   in the METRO separate fund as specified herein.  It is expressly understood and
   •greed that in no event will the AGENCY contribution exceed the $2,800.00 stated.

5. RESPONSIBLE STAFF MEMBERS - William Elman of the AGENCY and Robert W. Bues of
   METRO will be directly responsible for interagency coordination and the proper
   conduct of this'Agreement.

6. TERMINATION OF AGREEMENT - If for any cause, METRO or the AGENCY shall fail
   to fulfill their obligations, or if METRO or the AGENCY violate any part of
   this Agreement, the aggrieved party may notify the alleged violator of their
   intent to terminate this Agreement.  .If the violation has not been corrected
   within thirty  (30) days of the notice, the aggrieved party shall have the  right
   to terminate this Agreement by given written notice to the party who has al-
   legedly violated terms  of the Agreement at least ten  (10) days prior to the
   date of the termination.

7. INTEREST OF MEMBERS OF  THE AGENCY AND  OTHERS - No officer, member, or employee
   of the AGENCY or METRO  and no members  of their governing bodies shall partici-
   pate in any decision  relating to this  Agreement which affects their personal
   interests or the interest of any corporation, partnership, or association  in
   which said persons are  directly  or indirectly interested or have any personal
   or pecuniary interest,  direct or indirect, in this Agreement or the proceeds
   thereof.

8. OFFICIALS NOT TO BENEFIT  - No members  of or  Delegate  to the  Congress of the
   United States of America,  and no Resident  Commission, shall  be admitted to any
   share or part hereof  or to any benefit to  arise herefrom.

9. U.S.  EPA FUNDING AND  PARTICIPATION - This  Agreement  is funded  in part by a grant
   from the U.S.  Environmental  Protection Agency.  This  Agreement  is  subject  to
   regulations contained in  40  CFR Subchapter B and  particularly  Part 33 thereof.
   Neither the United States  nor the U.S.  Environmental  Protection  Agency  is  a
   party to this  Agreement.

10.  RIGHTS TO  DATA -  It  is understood by all  parties  contributing  personnel,
   equipment,  supplies,  personnel  or financial  support  to the project,  that all
   data,  tapes,  recordings,  logs,  or any  information collected, stored, evaluated,
   printed, or otherwise acquired  during  the completion of  the  project shall  be
    public property,  including tho  public  right  to use,  duplicate,  and disclose
    in whole  or  in part,  in any  manner  for any purpose,  or to have others do  so.
    METRO or  the  AGENCY  do not claim any exclusive rights, privileges, or access
    to said data  acquired during the term of  the project. METRO does  not have nor
   will it  have  responsibility  to  copy,  transfer,  store, collect,  or  file  any
    project  data,  nor does METRO accept  or assume  any responsibility for repre-
    senting  or organizing the project tlata in any  form suitable  for use on  any
    subsequent study,  survey, or filing  other than to preserve raw field data with
    reasonable diligence and care,  and to transfer said raw  field data to the
    custody of a duly designated depository.
                                      B-ll

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Page 3 of 3
   XM WITNESS WHBREQP. the AGENCY and METRO have caused thi» Ag
executed as of the data first written above.
                                        reeaent to be
    GREEN BAY METROPOLITAN
    •CHERAGE DISTRICT
    Robert W. Buee
    Project Director
                           FOX VALLEY HATER QUALITY
                           PLANNING AGENCY
                            Kathleen  Propp
                            Chairman
/tf
 r"
    Fred Whiting
    Project Coordinator
    River/Bay Study
                           William  R.  Elaan
                           Executive Director
Date
                                                  Date-
                                    B-12

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                                      RUDGFT SUMMARY
                            1982 River/Ray Monitoring Project

Item               GBMSD          FVWQPA         IRSC         Other         Total

Hardware           $37,500.00                                R,000.00        $45,500.00

Independent Water
   Duality Analysis                             40,500.00                    40,500.no

Service Contracts
 IISGS                3,850.00                                                 3,850.00
 HW-Mil-Ifie         70,850.00                                                70,850.00
 IlW-GP-Harris       17,460.00                                                17,850.00
 IW-GB-Sager         2,300.00                                                 ?,300.00
 Green Bay Wfestern
  Railroads            160.00                                                   160.00
 Development of
  Data Library       3,777.00   2,800.00     ^.____  	      6,577.00

                  $135,897.00  $2,800.00       $40,500.00   $8,000.00       $187,197.00
                                           B-13

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      MONMOUTH COUNTY HEALTH DEPARTMENT AND




NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
                      B-14

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                 COOPERATIVE MONITORING AGREEMENT

                             between
                 Monmouth  County Health Department

                               and
            New Jersey  Department of Environmental Protection
    The rapid expansion and increasing complexity of water monitoring
needs in New Jersey necessitates improved coordination and planning
among all agencies involved.  In recognition of this need, the Monmouth
County Health Department and the New Jersey Department of Environmental
Protection hereby agree to cooperate in the most effective and efficient
use of their respective water monitoring, laboratory analysis, and data
management resources.

     It is hereby agreed that the attached delineation of responsibilities
and summary of respective agency water monitoring activities accurately
describes the cooperative program for the year  1983, and represents the
most effective utilization of the combined resources available to the
participants.
                          B-15

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                                  1983

                  COOPERATIVE WATER MONITORING PROGRAM


      The  following information represents the planned contributions from the
  respective agencies for water monitoring during the year  1983.  It is understood
  that resource availability and program emphases may shift during the period of
  the agreement.  Accordingly, the program shall be reviewed jointly on a quarterly
  basis, and revisions made on notification of the cooperating agency.

  I.  Routine  Surface Water Monitoring

     A.  Monmouth County Health Department agrees to monitor and analyze
         samples from 47 stations throughout the county  for bacteriological
         and  chemical parameters as per Appendix 1.  Stations will be sampled
         on a monthly basis.  Data will be maintained in paper  files and made
         available  to DEP on a request basis.

     B.  N.J.D.E.P. agrees to monitor and analyze samples  from  13 stations
         throughout the county for bacteriological and chemical parameters
         as per Appendix 2.  Data will be stored on STORETand made available
         to the county on request.

     C.  N.J.D.E.P. agrees to provide technical assistance to the county in
         designing and evaluating monitoring networks, training and evaluating
         field procedures, and developing and implementing computer compatible
         data management practices.


 II.  Recreational/Bathing Area Monitoring Network

     A.  The  county health department agrees to monitor  recreational and bathing
         area waters  (is 19 locations) for bacteriological  quality during the
         period May  15 - September  15 on a weekly  basis.  Data  will be stored on
         file and made available  to DEP for incorporation  into  the C.C.M.P. report.

     B.  N.J.D.E.P. agrees to provide technical assistance in network design,
         field procedures, and data management.

     C.  N.J.D.E.P. agrees to include county data  in its annual C.C.M.P. Report,
         and  forward a copy  of the report to the health  department on an annual
         basis.


III.   Potable  Water  Network

      A.  The  county health department agrees to monitor  potable water supplies at
         seventeen  (17)  locations identified in Appendix 3,  for Safe Drinking
         Water Act  compliance on  a quarterly basis.

      B.  N.J.D.E.P. agrees  to provide technical assistance in evaluating
         data.
                               B-16

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IV.  Landfill Monitoring

     A.   The county health department agrees to monitor ovservation wells
         at the Howell Municipal Landfill on a quarterly basis for those
         parameters required by the Division of Waste Managemnt.   Data
         will be submitted to the Department of Environmental Protection
         in accordance with regulation requirements.

     B.   N.J.D.E.P. agrees to provide technical assistance in data
         evaluation and problem identification.
 V.  Intensive Surface Water Surveys

     A.  The county health department agrees to conduct streamwalk surveys
         on sixteen stream segments.

     B.  N.J.D.E.P. agrees to provide technical assistance and follow-up
         evaluation on problems identified in these surveys.

IV.  Laboratory Services/Quality Assurance

     A.  The county health department agrees to develop laboratory
         capabilities consistent with monitoring program needs and available
         resources.  Quality assurance practices in field procedures,
         laboratory analysis, and data management will be employed to insure
         the integrity and validity of generated data.

     B.  NJDEP agrees to provide technical support guidance, and training
         as requested by the county to assist in the development and imple-
         mentation of appropriate laboratory, data management, and field
         monitoring capabilities and procedures.
                                  B-17

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                APPENDIX C
   GUIDANCE FOR PREPARATION OF  COMBINED
   WORK/OUALITY ASSURANCE  PROJECT  PLANS
       FOR ENVIRONMENTAL MONITORING

              (ORWS OA - 1)
OFFICE OF WATER REGULATIONS AND STANDARDS
   U.S. ENVIRONMENTAL PROTECTION AGENCY
         WASHINGTON, D.C.  20460
               May, 1984

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          FORMAT AND DESCRIPTION FOR WORK/0 A PROJECT PLAN

     Title Page (With Project Officer, OA Officer and Agency/Division
         --Sig natures . ) *
1.   Project Name

2.   Project Requested By

3.   Date of Request

4.   Date of Project Initiation

5.   Project Officer

6.   Quality Assurance Officer

7.   Project Description


     The purpose of the project description is to define the

objectives (goals) of the project and describe how the project will

be designed to obtain the information needed to accomplish the

project goals.  The project description should consist of the

following :
     A.   Objective and Scope Statement

          This section should consist of a comprehensive statement

          addressing the project's objective (purpose) and an

          overview of the project's scope (activities).  Background

          information pertaining to the project (i.e., reconnaissance

          information) should be included.



     *    The exact format of this page will vary according to

          specific State organizations and their designated

          responsible individuals.


                              - C-l -

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B.   Data Usage
     This section should consist of a comprehensive statement
     outlining the intended data usage.   It is important to clearly
     indicate this usage so that suitable sampling, analytical  and
     QA/QC protocols are selected-  When applicable, secondary  uses
     of the data should be identified.  The following are examples of
     data uses:
                -  verify self-monitoring data;
                -  verify compliance with NPDES permit;
                -  support permit reissuance and /or revision;
                -  support other program elements such as water quality
                   standards; and
                -  possible usage in an  enforcement action.
C.   Monitoring Network Design and Rationale
     This section should address the design of the overall monitoring
     system, the specific locations of the sampling sites, and  the
     justification for the overall monitoring network design.  As
     discussed in Section II, data representativeness, comparability,
     and completeness should be considered an integral part of  the
     monitoring design.  Other relevant  factors which influence the
     design of the monitoring network should also be considered
     and reflected in the plan (e.g., homogeneity of the system
     under investigation, accessibility  of the sampling  area, stream
     flow conditions, tidal fluctuation, weather conditions).
                         - c - 2 -

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D.   Monitoring Parameters and Frequency of Collection
     This section should discuss the types of parameters to be
     collected at the various sampling sites.  This may be done
     in tabular form provided the following information is listed:
          - sampling site location (e.g.  latitude/longitude, River Mile
            Index, Depth);
          • type of sample (e.g.. grab sample, cross-sectional
            stream composite sample);
          - sample matrix (e.g., stream surface water, river bottom
            sediment);
          - parameters to be analyzed (e.g., copper, lead); and
          - sampling frequency.
     "Type of sample" should be only a brief description.  A
     detailed description of the sample collection method will be
     addressed in Item 12.
E.   Parameter Table
     This table should provide the following information for each
     parameter analyzed:
          - sample matrix;
          - analytical method reference;  and
          - sample holding time.
     The analytical method reference must correspond to that specific
     procedure which  is  followed  in the  laboratory  for the analysis
     of that  parameter  in that matrix.   If  an  EPA-approved method  is
     used, a  citation of the method's reference  is  sufficient.   If
                          - c.  3  -

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          no EPA-approved method is available or if the method to be used
          is a modification of an EPA-approved method, the method must be
          validated and documented in detail.  The documented method should
          be made part of the project plan by either incorporation into
          the laboratory's Standard Operating Procedures (SOP's) or by
          becoming an attachment to the project plan.

8.   Project Fiscal Information (Optional)*
To aid in the planning, control, and the allocation of existing resources
and to assist in the documentation and justification for future resources,
the financial requirements/expenditures for travel, per diem, mileage,
salaries and benefits, clerical services, expendable supplies, laboratory
services and any outside contractual arrangements should be delineated.
In addition, major equipment items such as automobiles, trucks, boats,
helicopters, drilling equipment, special safety equipment, etc., required
to implement the study plan for the project, should be specified and the
source and cost of each item identified.  A factor for administrative
overhead cost may also be computed to complete the fiscal picture.

9.   Schedule of Tasks and Products
The progress of the project from conception to implementation should be
followed.  It is necessary to plot each phase of the project contained
in the project schedule, from initial request to final project report.

*  This section is optional depending on existing State procedures.

                              - c . 4 .

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 This  includes:
      - the date  of  the  request  which  initiates  the  project;
      - the date  by  which the  project  plan  will  be submitted to all
        interested parties;
      - the date  by  which comments on  the plan are to  be  received  by the
        project officer;
      - the date(s)  of the field reconnaissance;
      - the date(s)  of the field sampling activities;
      - the date(s)  the samples will be submitted to the  laboratory for analysis;
      - the date(s)  by which all analyses are to be completed and the data
        submitted to the project officer;
      -  the date(s) the data will be entered into STORE! or other computerized
        systems;
      -  the  date of the completion of the draft interim/final project report;
      -  the  date by which the reviewers' comments on the report(s) must be received;
      -  the  date for completion of the peer review process; and
      -  the  date for the issuance of the final project report.
Each  step  in this process should be scheduled in an objective and realistic
time  frame to assure that adequate attention is devoted to the minimization
of effort and the maximization of information.
10.  Project Organization and Responsibility

In order for a monitoring study to proceed  smoothly  and yield  valid and
useable data, it  is  essential  that all individuals  are clearly informed.
                              - c- 5 -

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of their responsibilities.  The Project Organization and Responsibility
Section of the Work/QA Project Plan should, at a minimum, identify key
individuals responsible for:
     - sampling operations
     - sampling QC.
     - laboratory analyses
     - laboratory QC.
     - data processing activities
     - data processing QC.
     - data quality review
     - performance auditing
     - systems auditing (on-site.evaluations)
     - overall QA
     - overall project coordination

It is often useful on a project to indicate how these individuals relate
in the organization(s).  An organizational chart is a convenient way of
illustrating this.

For each key individual named, a brief sentence or two explaining
that  individual's responsibility should suffice.   Telephone  numbers should
be listed with the key individuals in order to facilitate communications.
Where there are several different  monitoring institutions or subcontractors
involved, complete addresses should be provided.
                              - c. 6 -

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11.  Data Quality Requirements and Assessments

     It is important in project planning that a cooperative effort be
undertaken by the project officer, sampling, and analytical personnel to
define what levels of quality shall be required for the data.  These data
quality requirements shall be based on a common understanding of the
intended use of the data, the measurement process, and availability of
resources.  Once data quality requirements are clearly established, QC
protocols shall be defined for measuring whether these requirements are
being met during the study.
As a minimum, requirements should be specified for detection/quantitation
limits, precision, and accuracy for all types of measurements, where
these are appropriate.  A procedure for determining method detection
limits is covered 1n "Methods for Organic Chemical Analysis for Municipal
and Industrial Wastewater," EPA 600/4-82-057.

Customarily, laboratory personnel provide the project officer with method
options covering a given parameter and type of sample.  These options are
accompanied by respective detection/quantitation  limits and statements of
precision and accuracy.  Once the method options  are selected, the detection/
quantitation limit, precision, and accuracy requirements should be
incorporated into the Work/QA Project Plan.  Along with each requirement,
there should be a protocol for monitoring whether these requirements were
met.  For example, intralaboratory precision can  be monitored by using
replicate samples.  Accuracy can be «o«itared *«t& ±&s use of fi£l4 £od
rnethod blanks, spikes, surrogate spikes, National Bureau of Standards'
Standard  Reference Materials  (SRM's), EPA QC reference samples, etc.
                               -  c  . 7  .

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Wherever possible criteria should be set for the "total  measurement."
This could be accomplished, for example, with the use of field replicate
samples.
Frequency of QC sample analysis and statistical  reporting units shall be
defined in the Work/QA Project Plan.
When discussing data quality requirements, consideration should also
be given to data representativeness, comparability,  and  completeness.

     - Representativeness is a quality characteristic.  For most water
       monitoring studies, it should be considered a goal to be
       achieved rather than a characteristic which can be described in
       quantitative terms.  An example of the need for representativeness
       is in the planning for the collection of  surface  water samples
       from a stream and the subsequent use of the data  for determining
       wasteload allocations.  The question to oe addressed is how the
       sample will be collected to ensure its relationship to the stream
       characteristics (i.e., the taking of grab samples in a restricted
       zone of the stream compared to a complete transect sampling).
     - Comparability is also a quality characteristic which must be
       considered in study planning.  Depending  on the end use of data,
       comparability must be assured in the project  in terms of sampling
       plans, analytical methodology, quality control, data reporting,
       etc.  For example, a comparability question would be whether
       analysis bas^tl on different portions of fish  are  comparable (i.«.,
       whole versus edible portions).
                               - c . 8 -

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     - Completeness  is a messure  of all  information  necessary  for a  valid
       scientific study.  A useful  way to  evaluate completeness  is to
       carefully compare project  objectives  with  the proposed  data
       acquisition and resulting  potential  "short falls"  in  needed
       information.   Generally,  it  is  not  useful  to  try  and  measure  this
       in quantitative terms for  most  water  monitoring projects.

12.  Sampling Procedures

For each environmental parameter  or parameter group  to be measured,  a
complete description of the sampling procedure must  be documented.
Included as vital elements in the sampling documentation should  be:
inclusion of specific sampling procedures, (by reference  to Standard
Operating Procedures or by detailed descriptions  of  state-of-the-art
methods, where used); flow diagrams or tracking mechanisms to  chart
sampling operations; and descriptions of sampling devices, sampling
containers, preservation techniques, sample  holding  times and  sample
identification forms.

13.  Sample Custody Procedures
Sample custody is a vital aspect of any monitoring program generating
data which may be used as evidence in a court of law.  In this regard, proper
procedures for the acquisition, possession, and analysis of samples  for
documenting violations of State and/or Federal regulations and/or statutes
are vital to the acceptance of such data in court.  This area is generally
referred to as the "chain-of-custody of samples".

                              - c - 9  -

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If the intended use of the data generated from this monitoring project
is enforcement related (see Item 78), then a detailed description of the
sample handling procedures utilized in the field, as well as the laboratory,
must be documented.  This procedure may be made part of the project plan
or, if documented in the Standard Operating Procedures (SOP) manual
(both sampling and laboratory SOP's), it may be incorporated by reference.

When documenting the sample chain-of-custody procedures, the following
information should be included:
     1.  Since chain-of-custody begins with the cleaning of the sample
         containers to be used, a written record of the laboratory's
         source and manner of preparation of all sample containers should
         be referenced.  This should include the laboratory's quality
         control procedures for assuring that the "cleaned" containers
         are truly decontaminated.
     2.  A detailed description of how sample containers are handled  (in
         both the field and laboratory) to prevent either inadvertent
         contamination or potential opportunities for tampering.
     3.  An example of the chain-of-custody form should be included with
         an explanation of the signing procedure.

14.  Calibration Procedures and Preventive Maintenance
The  purpose of this section is to document, by describing in detail or
referencing the appropriate SOP, methods which are utilized to assure
that field and laboratory equipment are functioning optimally.  The
frequency of application of these methods should also be appropriately
recorded.
                              - c .  10 .

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Exhibits 14.1 and 14.2 are examples of check lists for field and
laboratory equipment.
An equipment log book is to be maintained in addition to the check list.
The equipment log book shoul.d remain with the piece of equipment except
when the equipment is sent out for repairs,  rhe log book should contain
records of usage maintenance, calibration, and repairs.
                               Exhibit 14.1
                    Field Equipment Check List Example
Automatic Sample
Battery
Pump Tubing
Discharge Tube
Splash Shield
Bottles
Intake Nozzle
     Task
Clean and charge
Soak, scrub, rinse
Soak, scrub, rinse
Scrub, rinse
Clean, rinse, dry
Disassemble, clean, rinse
 Frequency
 After  each  sampling
 After  each  sampling
 After  each  sampli ng
 After  each  sampling
 After  each  sampling
 After  each  sampling
                               Exhibit  14.2
                  Laboratory  Equipment Check  List  Example
 Absorption
 Spectrophotometer
 Calibrate against
   standard
       Frequency
       Each nth
       determination
Identify Each Sample
Number and Date
Standard number 5.
11/10/82
 15.   Documentation,  Data  Reduction  and  Reporting

 The  purpose of this  section  is  to describe documentation,  data
reduction, and reporting:
                              - c - 11 -

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A.  Documentation - There must be adequate documentation available with
all data.  This is necessary to help in fully interpreting the data as
well as to protect it against legal and scientific challenges.  Records
must be legible, complete and properly organized.  In some cases, they
must be protected, using a document control system.
In the Work/QA Project Plan, SOP's should be referenced or included
which define the type of record to be maintained as well as indicating
where and how records will be stored.
B.  Data Reduction and Reporting - "Paper work" errors are commonly found
in the calculations, reductions and transfer of data to various forms and
reports and transmittal of data into data storage systems.  Quality
control procedures should be carefully designed to eliminate errors during
these steps.  Calculation procedures should be described, to the extent
possible, in analytical SOP's.  SOP's should be referenced in the Work/QA
Project Plan which describe review and cross-check procedures for
calculations.  Also, the SOP's should completely cover the step-wise
procedures for entering data onto  various forms and into computer systems.
In addition to handling data, procedures should cover routine data transfer
and entry validation checks.  Where data forms are a^ed, they should
be included in the SOP's.
16.  Data Validation
Each program must establish technically sound and documented data validation
criteria which will serve to accept/reject data  in a uniform and
manner.
                              - c  . 12 -

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Data validation can be envisioned as a systematic procedure of reviewing
a body of data against a set of established criteria to provide a specified
level of assurance of its validity prior to its intended use.

Data validation is, of necessity, conducted "after the fact."  It requires
that the techniques utilized are applied to the body of the data in a
systematic and uniform manner.  The process of data validation must be
close to the origin of the data, independent of the data production
process, and objective in approach.

Criteria for data validation must include checks for internal
consistency, checks for transmittal errors, checks for verification of
laboratory capability, etc.  These criteria involve utilization of
techniques such as interpretation of the results of:  external performance
evaluation audits; split sample analyses; duplicate sample analysis (field
and laboratory); spiked addition recoveries; instrument calibrations;
detection limits; intra-laboratory comparisons; inter-laboratory com-
parisons; tests for normality; tests for outliers; and data base entry
checks.
17.  Performance and System Audits
Performance and systems audits are an essential part of every quality
control program.  A performance audit independently collects measurement
data using performance evaluation samples.  A systems audit consists of a
review of the total data production process which includes on-site reviews
of a field and laboratory's operational systems and physical facilities
for sampling, calibration and measurement protocols.
                               - c. 13 .

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To the extent possible, these audits should be conducted by individuals
who are not directly involved in the measurement process.  Audits serve
three purposes:

     (1)  to determine if a particular group has the capability to conduct
          the monitoring before the project is initiated;
     (2)  to verify that the QA Project Plan and associated SOP's are being
          implemented; and
     (3)  to detect and define problems so that immediate corrective action
          can begin.
A Work/QA Project Plan should specify who will conduct the audit, what
protocol will be used, what the acceptance criteria will be and to whom
the audit reports will go.  Generally, the dates for conducting the
audits should be listed unless it is decided to conduct these unannounced.
Performance evaluation samples produced by EPA-can be used as a type
of performance audit.  These samples can also be obtained from the
National Bureau of Standards, United States Geological Survey  commercial
sources or in-house sources.  Generally, it should not be necessary to
conduct these audits if the group being tested has successfully performed
within the last 6 months for the particular parameters in que^cion.
18.  Corrective Action
A corrective action program, which must have the capability to discern
errors or defects at any point in the project implementation process, is
an essential management "tool for 1>oth project coordination and TJuaTHy
Assurance/Quality Control activities.

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A plausible corrective action scheme must be designed to Identify defects,
tally defects, trace defects to their source, plan and implement measures
to correct identified defects, maintain documentation of the results of
the corrective process, and continue the process until each defect is
eliminated.

Each organization must develop a corrective action protocol which is
technically effective as well as administratively compatible.

19.  Reports
Formal reports must be issued to inform appropriate management personnel
of progress in the execution of the work plan.  The reports should include
an assessment of the status of the project in relation to the proposed
time table.  The reports should also address any results of ongoing
performance and systems audits, data quality assessments, and significant
quality assurance problems with proposed corrective action procedures.
The  final  report shall be issued, consistent with the rationale for
executing  the Work/QA Project Plan.  The report shall also include appropriate
data quality assessment.
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