MPCA quality system

The Quality Management Plan (QMP) documents the MPCA's strategy for building quality into all its programs. The quality systems include planning, implementing, and assessing the quality assurance and quality control operations as they are applied to the MPCA's environmental data programs. The QMP is reviewed by EPA Region 5 QA Managers to ensure that all elements of the EPA QMP guidance document are adequately addressed. The QMP is to be renewed every five years or sooner if significant changes are made to QMP program elements.

The MPCA's quality system encourages staff to resolve problems in a timely manner. Staff are responsible for planning, executing, documenting and reviewing all work performed to ensure that it conforms to the DQO process. Supervisors assist staff to ensure all facets of the problem are considered and the best options used. The QACs are responsible for writing quality-related policies, which are then incorporated by staff into their Work Plans and QAPPs.

Each MPCA environmental monitoring program's work follows an approved Quality Assurance Project Plan (QAPP), Work Plan, and Standard Operating Procedures (SOPs), which are part of the QMP.

• Quality Management Plan (p-eao2-15)
• EPA's Quality System

A QAPP agreement between a regulator, grantee, responsible party, the consultant, the laboratory, and other interested parties concerning what work will be performed, how it will be performed, why the work is being performed, the analytical methods used, and the quality assurance used.

Guidance

• MPCA Quality Assurance Project Plan Guidance (p-eao2-13)
• EPA Requirements for Quality Assurance Project Plans
• Wild Rice Sulfate Standard Hydroponic Experiment on the Response of Wild Rice to Sulfate - Quality Assurance Project Plan (tdr-qapp1-01)
• Wild Rice Sulfate Standard Mesocosm Studies - Quality Assurance Project Plan (tdr-qapp1-02)
• Wild Rice Sulfate Standard Hydroponic Experiment on Response of Wild Rice to Sulfide QAPP (tdr-qapp1-03)
• Minnesota Wild Rice Sulfate Standard 2013 Field Survey QAPP (tdr-qapp1-04)
• Wild Rice Sulfate Standard Sediment Incubation Experiment QAPP
• Calibrating Concerns about PAHs in Urban Air QAPP
• Pyriproxyfen In Water Quality Assurance Project Plan
• Ecotoxicogenomic Study of the Effects of Exposure to Surface Water on Daphnia Pulex QAPP
• Bisphenol A in Thermal Paper Quality Assurance Project Plan (p-p2s1-07)
• Bisphenol S in Thermal Paper Quality Assurance Project Plan (p-p2s1-08)
• Quality Assurance Project Plan for the Nutting Truck and Caster Site (c-rem3-09)
• 2017 National Lake Assessment Project QAPP (wq-nlap1-16)
• Carver County Compost Facility Groundwater Monitoring QAPP (p-eao2-24)

Examples

• Underground Storage Tank and Petroleum Remediation Quality Assurance Program Plan (p-eao2-04)
• TSCA PCB Quality Assurance Program Plan (p-eao2-08) (Attachments 1-6 are on file at the MPCA)

A SOP describes the procedures to perform a given operation, task or project. All sampling and analytical procedures are documented in the Standard Operating Procedures (SOPs) and the MPCA sampling guidance documents. The MPCA writes SOPs for critical tasks that merit standardization. The program QAC typically writes the SOPs with input from knowledgeable staff.

The QAC gives the SOPs final review and approval. Outdated SOPs are updated and rewritten. The QAC also reviews and approves the updated SOP. The Guidance on the creation of a SOP can be found in the MPCA's QMP as well as in EPA Guidance for Preparing Standard Operating Procedures (SOPs), EPA QA/G-6.

Guidance

• EPA Guidance for Preparing Standard Operating Procedures (SOPs)

Examples

• Lake monitoring SOP
• Standard operating procedures (SOP) for household hazardous waste programs

Lab references

• Guidance for Comparability Studies for Ammonia
• Laboratory Data Checklist Guidance (p-eao2-11a)
• Laboratory Data Review Checklist (p-eao2-11b)
• Minnesota Department of Health Environmental Laboratory
• Laboratory Quality Control and Data Policy
• Methods and Analytes Requiring Laboratory Certification
• Polycyclic Aromatic Hydrocarbons
• Alternate Test Procedure Guidance
• Risk-Based Guidance for Tier 1 and 2 SRVs
• MPCA's Lab Registration Program
• Total Nitrogen for NPDES/SDS Reporting
• Total Kjeldahl Nitrogen for NPDES/SDS Reporting

Local professional organizations

• Minnesota Chromatography Forum
• Minnesota Mass Spectrometry Discussion group
• American Chemical Society - Minnesota Local Section

Project-specific guidance

Remediation Division

• Remediation Division Policy on Analysis of Carcinogenic Polynuclear Aromatic Hydrocarbons (cPAH)

Petroleum Remediation Section

• Underground Storage Tank and Petroleum Remediation Quality Assurance Program Plan
• 4-01 Soil and Groundwater Assessments Performed during Site Investigations (c-prp4-01)
• 4-01a Vapor Intrusion Assessments Performed during Site Investigations (10/10)
• 4-01c Intrusion Screening Values (10/10)
• 4-04 Soil Sample Collection and Analysis Procedures (c-prp4-04)
• 4-05 Ground Water Sample Collection and Analysis Procedures (c-prp4-05)
• Investigation Requirements for Ethanol-blended Fuel Releases (7/10)
• 7-09a Air Emission Controls (1/11)
• Changes to Petroleum Remediation Program Guidance

Dredged materials management

• Managing dredged materials in the state of Minnesota

PCBs

• 40 CFR 761 PCBs
• PCBs - sealants and coatings (5/13)

Perfluorochemicals

• Guidance for perfluorochemicals analysis (p-eao2-06)

Hazardous waste

• TCLP - MN Rule 7045.0131

Spills and clean up

• PCB Spill Cleanup Policy (3/12)

EPA method references

• SW-846
• Clean Water Act Analytical Methods
• Other CWA Methods Not Approved for use at 40 CFR 136
• Forum on Environmental Measurements
• CFR Promulgated Test Methods
• 40 CFR 136 — Guidelines Establishing Test Procedures for the Analysis of Pollutants
• Memo on Flexibility to Modify CWA Methods (11/07)
• QA/QC Requirements in Methods not Published by EPA
• Solutions to Analytical Chemistry Problems with Clean Water Act Methods
• National Functional Guidelines (Superfund)

• EPA Indoor Air Unit Conversion

• Data Quality Objectives Guidance (p-eao2-14) (3/12)

Please submit questions to qa.questions.mpca@state.mn.us

Q: What is the MPCA's guidance on using clean-up methods to overcome possible matrix interferences in the DRO analysis?
A: In the past, the MPCA has provided the following guidance on using clean-up methods to overcome matrix interferences:

The Wisconsin Department of Natural Resources Diesel Range Organics (DRO) analysis method can have false positives that lead to elevated results, which are not from petroleum compounds. The DRO analysis method is a very useful screening method, but may not provide an accurate determination of petroleum compounds for making site decisions. When false positives are suspected, cleanup of extracts to remove non-petroleum compounds may be necessary. The two cleanup methods allowed can be used separately or in combination. The methods for cleaning up the extracts prior to analyzing them for DRO are: 1) EPA Method 3630C, silica gel cleanup method and 2) EPA Method 3650B, acid/base partitioning. The results obtained from utilizing the cleanup methods will only be accepted if quality assurance documentation shows results that meet acceptance criteria (i.e., no significant loss of petroleum compounds). The quality control acceptance criteria for the cleanup results will be as follows: At least one method blank, one laboratory duplicate, one matrix spike, and one laboratory control sample must be run through the complete cleanup and analyses process for up to 20 samples (1/20). The laboratory must provide a narrative of the entire cleanup and analysis process. They must also compare the pre-cleanup chromatogram with that of the post-cleanup chromatogram. The Relative Percent Difference (RPD) between sample duplicates, matrix spike pairs, or laboratory control sample pairs must be less than or equal to 20%. However, if the concentration of the target analyte in the sample/sample duplicate is less than five times the report level, the difference between duplicates is used to measure precision. The difference must then be less than or equal to the report level.

These allowed methods are to be used after the initial analysis in order to evaluate the potential of false positives being reported.

Q: Does percent moisture have a specified holding time? Initial investigations into the Code of Federal Regulations, Part 136 Table II or Chapters 2, 3, or 4 of the SW-846 methods do not provide specific holding times for percent moisture. Does anyone know of a method or reference that provides a specific percent moisture holding time?
A: Section 7.5 of EPA Method 5035 states the following: “There is no holding time associated with the dry weight determination. Thus, this determination can be made any time prior to reporting the sample results, as long as the vial containing the additional sample has remained sealed and properly stored."

Q: What is the MPCA recognizing as the holding time for 8082?
A: Chapter 4 of the SW846 Manual indicates that there is no holding time for PCBs in any matrix. Containers, preservation techniques, and holding times should be based on project-specific data quality objectives. Rules, permits, MPCA program requirements, or QAPPs may also define holding times that are more stringent than Chapter 4. However, per the method, the holding time between extraction and analysis should be 40 days or less.

Q: How should laboratories deal with samples where holding times have been exceeded (for those analyses that are listed as “15 minutes” in 40 CFR 136)?  Some of these are pH, ortho-phos (filtering), etc.
A: 40 CFR Part 136 establishes guidelines for test procedures for the analysis of pollutants under the Clean Water Act. It should be noted that sample preservation procedures, container materials, and maximum allowable holding times for parameters are cited in Tables IA, IB, IC, ID, IE, IF, and IG are prescribed in Table II.  Information in the table takes precedence over information in specific methods or elsewhere.  Any person may apply for a variance from the prescribed preservation techniques, container materials, and maximum holding times applicable to samples taken from a specific discharge. Applications for variances may be made to the MPCA (who will forward the request along with their recommendation to the US EPA Region 5). Sufficient data should be provided to assure such variance does not adversely affect the integrity of the sample.   Upon receipt of the recommendations from the Alternate Test Procedure Program Coordinator, the Regional Administrator may grant a variance applicable to the specific discharge to the applicant.

In Table II of 40 CFR 136, the following parameters have a maximum holding time of 15 minutes from sample collection to analysis: total residual chlorine, pH (hydrogen ion), dissolved oxygen (probe), and sulfite while samples for orthophosphate analysis must be filtered within 15 minutes of sample collection and then analyzed within 48 hours. Per the MPCA QC Policy, laboratories must verify that samples are received in the proper container with any applicable preservative in time to comply with the method or Program holding time requirement. Laboratories are required to qualify data that does not meet method or Program holding times and/or preservation requirements.

Q: Will a laboratory need to do anything to comply with the new policy?
A: No, not if the laboratory is currently certified by the MN Department of Health, no changes will be required.

Q: What is different between the new policy and the 2001 certification policy?
A: The MPCA is updating the certification policy because the 2001 policy contains old information. The new policy specifically lists analytes and methods the MPCA requires to be certified for analytical work performed for the MPCA, information on Alternate Test Procedures, and a list of states and programs that will be acceptable for primary certification for MPCA work.

Q: What does the MPCA require of a state or program to be found acceptable?
A: The state or program must meet minimum certification requirements as listed in the policy. Primarily, the certification program must be willing to have open dialogue with MPCA on issues found with laboratories and use the MPCA QC Policy in auditing. The QC Policy requires bench level data auditing by the accreditation body (AB) to verify the referenced method is being followed. The MPCA will be contacting states and programs throughout September to verify they are willing to work with the MPCA to meet the requirements of the Agency.

Q: When will the list of states and programs acceptable to the MPCA be published?
A: The list is anticipated to be published by the end of September / Early October. Note, the list is anticipated to be updated every year by July 1.

Q: What will happen with permits that require certification by MN Department of Health?
A: This issue is currently being studied. Permits are anticipated to be updated to reflect the new policy after the policy is published. Because permits are in effect for up to five years, it may take several years for all permits to be updated. The MPCA is looking at options to speed the process. Other fact sheets and documents will be updated over time.

Q: Will MPCA accept secondary certification from states found to be acceptable?
A: No, the MPCA only is concerned with primary accreditation, as in who is auditing the laboratory on site, reviews performance testing samples, and administers primary certification to the laboratory.

Q: Will the holding time for analytical data change in the master contract from ten to five years?
A: Yes, the MPCA will amend the contract this fall to reflect the QC Policy of holding analytical results for five years.