Attachment 6 - Quality Assurance Plan Briggs Creek.pdf

QUALITY ASSURANCE PLAN

FOR EFFLUENT MONITORING

AT

BRIGGS CREEK WEST FISH HATCHERY

NPDES GENERAL PERMIT NUMBER IDG-130000

Facility ID # IDG-130054

Updated 1/14/2025

Table of Contents

1.0. PROJECT MANAGEMENT

1.1. Title and Approval Sheet

1.2 Distribution List

1.3 Project Organization

1.4 Problem Definition/Background

1.5 Project/Task Description

1.6 Quality Objectives and Criteria for Measurement Data

1.7 Special Training Requirements/Certification

1.8 Documentation and Records

2.0 DATA GENERATION AND ACQUISITION

2.1 Sampling Process

2.2 Sampling Methods

2.3 Sample Handling and Custody

2.4 Analytical Methods

3.0 DATA MANAGEMENT

3.1 Assessment and Response Actions

4.0 DATA VALIDATION AND USABILITY

4.1 Data review, Verification and Validation

5.0 Diagram of Water Flow through the Fish Hatchery

5.1 Hatchery Site Plan Denoting Sampling Locations

5.2 Signatory Page

5.3 QAP Certification

1.0. PROJECT MANAGEMENT

1.1. Title and Approval Sheet

Name: ___________________________ Title: _______________________ Date: __________________

Name: ___________________________ Title: _______________________ Date: __________________

Name: ___________________________ Title: _______________________ Date: __________________

Name: ___________________________ Title: _______________________ Date: __________________

Name: ___________________________ Title: _______________________ Date: __________________

1.2 Distribution List

Name: _____________________________________________________________________ Title: _____________________________________________________________________ Organization: _______________________________________________________________ Contact Information (Address, Telephone, E-mail): _________________________________

Name: _____________________________________________________________________ Title: _____________________________________________________________________ Organization: _______________________________________________________________ Contact Information (Address, Telephone, E-mail): _________________________________

Name: _____________________________________________________________________ Title: _____________________________________________________________________ Organization: _______________________________________________________________ Contact Information (Address, Telephone, E-mail): _________________________________

Name: _____________________________________________________________________ Title: _____________________________________________________________________ Organization: _______________________________________________________________ Contact Information (Address, Telephone, E-mail): _________________________________

1.3 Project Organization

Briggs Creek West Fish Hatchery (BCWFH) is owned by Irle Ranch Inc. The facility is operated under contract by the Idaho Department of Fish and Game (IDFG). IDFG staffs the facility with one permanent employee on a rotational basis from the Nampa Fish Hatchery. IDFG is named as the NPDES permittee effective June 1, 2024. IDFG staff is responsible for proper implementation of this quality assurance plan, as well as sample collection, monitoring, recordkeeping, reporting, quality assurance, accuracy and compliance with the terms and conditions of NPDES Permit

#IDG-130000.

All permanent BCWFH staff are qualified to perform the sampling procedures required by the Idaho Aquaculture NPDES Permit #IDG-130000. The Fish Hatchery Manager is responsible for on-site quality control of sampling procedures.

1.4 Problem Definition/Background

BCWFH is a coldwater aquaculture facility which uses conventional linear concrete raceways for fish production, two offline ponds and an evaporation basin for waste treatment. BCWFH produces 300,000 pounds of harvestable fish annually and will therefore follow the quarterly monitoring guidelines for Total Suspended Solids (TSS) and Total Phosphorous (TP) established for hatcheries with raceways and associated full-flow settling basin discharge. BCWFH has been issued a wasteload allocation with seasonal effluent limitations measured in pounds per day for TSS and TP. BCWFH will report quarterly TSS and TP data and monthly flow data on the Discharge Monitoring Reports (DMRs). Chelated copper and copper sulfate are not used at

BCWFH.

1.5 Project/Task Description

Pursuant to the terms of NPDES General Permit #IDG-130000, flow must be monitored on a monthly basis while total suspended solids (TSS) and total phosphorus (TP) are to be monitored at least quarterly.

Sampling Frequency of Permit Compliance Monitoring for Aquaculture Facilities

Facility Classification Parameter Frequency Minimum Interval Between Sampling Events

Class 3:

Aquaculture facility either producing greater than or equal to 100,000 and less than 500,000 lbs/yr fish or with annual feed usage of less than 600,000 pounds but more than 120,000 pounds dry weight.

Flow 1/month 14 days

TSS 1/quarter 60 days

TP 1/quarter 60 days

The average monthly and maximum daily limitations for net TSS and net TP concentration in the discharge stream vary according to a trimester schedule. Water is decanted from the off line settling basins into a decanting pond, prior to cleaning the settling basins as needed.

All DMR forms are entered and submitted electronically through NetDMR. In addition, copies of all records will be retained on site for a period of no less than five years.

1.6 Quality Objectives and Criteria for Measurement Data

The overall objective of this plan is to provide known, defensible data to EPA and IDEQ for purposes of monitoring hatchery effluent levels pursuant to the provision of the Clean Water Act, based on total phosphorus and total suspended solids waste load allocations for all aquaculture facilities in the mid-Snake River, Idaho. Samples will be collected following strict sampling protocols to ensure they are representative of the effluent stream. One of the four samples will be taken during quiescent zone cleaning. All collected samples are taken to Magic Valley Labs upon completion of sample collection.

BCWFH intends to use Magic Valley Labs for all laboratory analysis. Magic Valley Labs fulfills all laboratory-specific quality assurance requirements for testing water samples described in the Idaho Aquaculture NPDES General Permit #IDG-130000. A complete and current set of standard operating procedures are maintained at Magic Valley Labs and followed during each test. These operating procedures address proper sample collection, preservation and storage, testing methods for each required parameter, calibration, operation and maintenance of equipment, and accurate data entry, correction, storage and transfer. A copy of these procedures is available from the lab upon request.

In addition, BCWFH will purchase a known total phosphorous sample from ERA, 16341 Table Mountain Parkway, Golden, CO 80403/phone 303-431-8454 and submit the sample to Magic Valley Labs for testing. This is to test the labs precision and accuracy of Magic Valley Labs. The results of this test will only be sent to BCWFH.

1.7 Special Training Requirements/Certification

Training is itemized in the EPA Training Folder in the hatchery office. Hatchery personnel assigned to compliance monitoring duties will receive on-the-job training in proper sample collection and handling and data entry from the Fish Hatchery Manager or other qualified BCWFH personnel. Employees will also be required to read and understand this QA Plan and the BMP Plan annually for the BCWFH facility (see Appendix A for the signatory page). The Fish Hatchery Manager is responsible for providing, overseeing and documenting training to staff.

1.8 Documentation and Records

BCWFH personnel will use facility specific data sheets to record all data collected including date, time, parameter sampled, handler/sampler, and chain of custody. Results of laboratory analysis will be reported using the Net DMR online system. Copies of all DMRs and associated data sheets will be retained on site.

2.0 DATA GENERATION AND ACQUISITION

2.1 Sampling Process

BCWFH produces approximately 300,000 pounds of harvestable fish annually and will therefore follow the quarterly monitoring guidelines for total suspended solids (TSS), flow and total phosphorous (TP) established for hatcheries with raceways. Compliance monitoring parameters and minimum sampling frequency as stated in NPDES General Permit #IDG-130000 are summarized in Table 1.

Table 1. Raceway and associated full-flow settling basin discharge monitoring requirements for facilities producing between 100,000 and 500,000 pounds of harvestable weight of fish annually.

Parameter Location Minimum Freq. Sample Type Total Suspended Solids influent and effluent quarterly composite to lab Total Phosphorus influent and effluent quarterly composite to lab Flow influent and effluent monthly approved method

As stated in NPDES General Permit #IDG-130000, BCWFH has been assigned annual effluent limitations based on the 2005 waste load allocations. The effluent limitations are based on seasonal values established for the year (Table 2). TSS and TP data will be monitored and reported at least once each quarter. If multiple samples are collected within the quarter, then samples will be analyzed in groups by month to calculated average monthly and maximum daily values for each month. BCWFH will report the results of any additional monitoring to EPA as required by section V.D. of the permit.

Table 2. Effluent Waste Load Allocation limitations for BCWFH.

Months

Net TSS Average Monthly (lbs/day)

Net TSS Maximum Daily (lbs/day)

Net TP Average Monthly (lbs/day)

Net TP Maximum Daily (lbs/day)

January-December 1892.1 3594.9 31.0 45.9

2.2 Sampling Methods

Total Suspended Solids Water samples for total suspended solids analysis will be collected using 4 grab samples over an 4-8 hour period, or at a minimum one grab every hour, at influent location BW Influent and effluent location BW Effluent Appendix 2. Each composite sample will consist of a minimum of four (4) discrete aliquots, collected over a 4-8 hour period, in clean glass or plastic bottles which have been washed with a non-phosphate cleaner and rinsed with distilled water prior to use. One of the four samples will be taken during quiescent zone cleaning. Samples will be refrigerated to ≤6⸰C after collection and transported to the laboratory. A one-liter sub-sample of the composite will be collected and sent to Magic Valley Labs in Twin Falls, Idaho for analysis. Please see section 2.3 below for sample shipping protocols.

Flow Inflow to the BCWFH facility raceways will be measured with a staff gauge located at the flume of the diversion for Briggs Creek West. Flow measurements will be reported monthly or in conjunction with composite sampling for other parameters, when monitoring for those parameters is required.

Total Phosphorous All water samples for total phosphorus analysis will be collected at locations 001, 002, (see Appendix 2). Each composite sample will consist of a minimum of four (4) discrete aliquots collected over a 4–8 hour period in clean glass or plastic bottles which have been washed with a non-phosphate cleaner and rinsed with distilled water prior to use. One of the four samples will be taken during quiescent zone cleaning. Total Phosphorous samples will be collected with the addition of sulfuric acid (H2SO4) and shipped to the Magic Valley Laboratory at ≤6 degrees Celsius within 48 hours of the last sample collection. The addition of H2SO4 must be added immediately to lower the pH to less than 2 at the time of collection. Samples will be refrigerated to ≤6⸰ C as required by EPA protocol after collection and then transported to the laboratory. In turn, Magic Valley Laboratory personnel will state on the chain of custody form that all total phosphorus samples were received at a pH of ≤2 and the receiving temperature was ≤6⸰C.

On an annual basis hatchery personnel will submit duplicate samples which are additional replicates of samples that are subjected to the same preparation and analytical scheme as the original sample. Depending on the method of analysis, either a duplicate sample aliquot or a matrix spiked sample are analyzed. The relative percent difference between duplicate analyses is a measure of the precision for a given method and analytical batch. The relative percent difference (RPD) is calculated as follows:

Relative Percent Difference: ((Sl-S2) X2i (Sl+S2)) Xl00

Hatchery personnel will provide QA/QC with all of our results and will put that on the COC for each set so that we can ensure it is included when the results are completed.

Quality Assurance field samples will be conducted on an annual basis. We will perform one test annually that measures precision and one test that measures accuracy of our labs. The precision test can be performed by splitting one of our samples and submitting as a duplicate. The accuracy test can be performed by ordering a known total phosphorus sample from the lab below.

Directions for Ordering a QA/QC Sample

1) Contact ERA Labs to set up an account for your hatchery.

a. Jennifer Watson 16341 Table Mountain Parkway Golden, CO 80403 www.eraqc.com Jennifer_watson@waters.com

2) Order a Catalog #525 Complex Nutrients, Waste WatR Relabel Stock for Total Phosphorus P.

a. One 15 mL screw cap vial.

b. Make sure to let Jennifer know you do not want your lab to be able to call ERA Lab and get the results. This prevents the possibility of your lab to be able to cheat.

ERA will relabel the sample vial to prevent this from happening before it is shipped out.

3) Have ERA Lab mail the sample directly to your laboratory.

4) Have the Certificate of Analysis from ERA Lab sent directly to you and not your lab.

a. This prevents your lab from cheating as they will not know what the results should be ahead of time.

5) Once your laboratory submits the results back to you, follow up with them and let them know if they passed or not. The results will be include in our Quality Assurance Plan.

We will plan on sending in one of these samples on an annual basis to continue to test the accuracy and precision of our lab and to adhere to the requirements of our NPDES permit.

2.3 Sample Handling and Custody

All sample containers will be labeled with proper sample location, sample number, sample type, sample date, parameter to be tested, sample temperature and the initials of the person collecting the sample. BCWFH personnel will also complete a chain of custody form to ensure proper sample handling and identification.

2.4 Analytical Methods

Table 3 depicts the analytical methodology and holding time criteria recommended by the U.S.

EPA. All samples will be handled in a manner consistent with these requirements. Magic Valley Labs fulfills all laboratory-specific quality assurance requirements for testing water samples described in NPDES General Permit #IDG-130000. A complete and current set of standard operating procedures are maintained at Magic Valley Labs and followed during each test. Assays performed are taken from Methods for Chemical Analysis of Water and Wastes, U.S. EPA, 1983:

TSS Method 160.2 (MDL 2.0 ppm), Total Phosphorus Method 365.2 (MDL 0.005 ppm).

For further information, Magic Valley Labs, may be contacted at the following address:

Magic Valley Labs 210 Addison Ave Po Box 1867 Twin Falls, ID 83301

(208) 733-4250 Brenda Ellis Laboratory Supervisor

Table 3. EPA sampling and analytical requirements.

Parameter Method Method Detection Limits Preservation Volume and

Container Holding Time

Total Phosphorus/ Influent & Effluent

EPA

365.2 0.005 mg/l Cool to 6o C

H2SO4 to pH<2 1 liter HDPE 28 days

Total Suspended Solids/Influent &Effluent

EPA

160.2 2.00 mg/l Cool to 6o C

1 liter

HDP

E

7 days

3.0 DATA MANAGEMENT

Laboratory analysis results will be reported to the BCWFH Fish Hatchery Manager who will check the data for completeness and accuracy. Data will also be entered into the hatchery electronic database. All data calculations will be completed using the effluent calculation formulas listed in Appendix D of NPDES General Permit #IDG-130000. To minimize possible calculation errors all calculations, including flow proportioning, are completed by entering raw data into an Excel spreadsheet that contains the effluent calculation formulas referenced above.

3.1 Assessment and Response Actions

The purpose of QA Plan assessment is to ensure that the plan is implemented correctly. All personnel involved with plan implementation will read and understand this QA Plan and the BMP Plan for BCWFH. In addition, they will review applicable procedures in Standard Methods for the Examination of Water and Wastewater (1998) and the terms and conditions of NPDES General Permit #IDG-130000 pertaining to BCWFH. Hatchery personnel will periodically double check each other’s procedures for consistency. Finally, compliance inspections will be performed by EPA or Idaho DEQ personnel at their discretion. Any procedural problems identified during these inspections will be corrected immediately.

4.0 DATA VALIDATION AND USABILITY

4.1 Data Review, Verification and Validation

BCWFH personnel that is responsible for sample collection, data entry and record keeping will also enter the DMRs into the NET DMR website. All DMRs will be reviewed by the BCWFH Fish Hatchery Manager for accurate calculations and outliers or nonsensical results prior to submission to EPA. Any errors will be traced to their origin and corrected. Significant errors will be reported to EPA as necessary.

Filloon,Brandon Nampa, is this how you are calculating?

5.0 Diagram of Water Flow through the Facility

Staff gauge location

5.1 Hatchery Site Plan Denoting Sampling Locations

5.2 Signatory Page

I have read and understand this Quality Assurance Plan for Briggs Creek West Hatchery

Name: ___________________________ Title: _______________________ Date: __________________

Name: ___________________________ Title: _______________________ Date: __________________

Name: ___________________________ Title: _______________________ Date: __________________

Name: ___________________________ Title: _______________________ Date: __________________

Name: ___________________________ Title: _______________________ Date: __________________

Name: ___________________________ Title: _______________________ Date: __________________

Name: ___________________________ Title: _______________________ Date: __________________

Name: ___________________________ Title: _______________________ Date: __________________

Name: ___________________________ Title: _______________________ Date: __________________

Name: ___________________________ Title: _______________________ Date: __________________

Name: ___________________________ Title: _______________________ Date: __________________

5.3 QAP Certification

Idaho Aquaculture Quality Assurance Plan (QA Plan) Certification

Facility Name: Briggs Creek West Fish Hatchery

Facility ID #: IDG-130054

NPDES Permit Number: IDG-130000

The QA Plan is complete and is available upon request to EPA and IDEQ.

The QA Plan is being implemented by trained employees.

The QA Plan has been reviewed and endorsed by the facility manager.

The individuals responsible for implementation of the QA Plan have been properly trained.

“I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.”

Signature:

Title/Company: Hatchery Manager/Idaho Fish and Game

Print Name:

Date: 05/13/2024

An existing discharger must submit this certification within 90 days of the effective date of this permit. For a new permittee, this certification must be submitted no later than the written Notice of Intent to be covered under this permit. The certification must be submitted to EPA and to the responsible IDEQ office (§I.C.1 of the permit).