kansas city, missouri...kansas city, mo partial year report stormwater npdes permit mo 0130516...

KANSAS CITY, MISSOURI

National Pollutant Discharge Elimination System (NPDES)

Municipal Separate Storm Sewer System (MS4)

Municipal Stormwater NPDES Permit MO-0130516

Partial Year Report

September 1, 2004 – April 30, 2005

Kansas City, MO Partial Year Report

Stormwater NPDES Permit MO 0130516 September 3, 2004 – April 30, 2005

Final 12/22/05

CERTIFICATION

Authority

As required in Part VI, Sections D and E, of Missouri State Operating Permit No. MO-

0130516,

All reports required by the permit and other information requested by the

Director shall be signed by:

1. For a municipality, State, or other public agency: either a principal

executive officer or ranking elected official.

Certification

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 gathered and evaluated 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 fines and

imprisonment for knowing violations.

______________________________________ ____________

Franklyn W. Pogge Date

Director

Water Services Department



Final 12/22/05

WRITTEN NOTICE OF COMPLIANCE

Part IV.B of the Missouri State Operating Permit MO-0130516 requires the City of

Kansas City, Missouri provide written notice of compliance or non-compliance with the schedule

for permit implementation. This first reporting period covers a partial permit year, September 3,

2004 – April 30, 2005. As this reporting period does not cover the entire first permit year,

September 3, 2004 – September 2, 2005, not all requirements of permit year one had been

completed within this first reporting period, and, therefore, are not reported on in this partial year

report, as provided for in Part VI.D of the permit. Any remaining first permit year requirements

will be addressed in the next report. As such, the City is in compliance with the schedule for all

interim milestones and final deadlines as identified in the permit schedule (Permit Part IV.A).



Final TOC-1 12/22/05

TABLE OF CONTENTS

CERTIFICATION

WRITTEN NOTICE OF COMPLIANCE

LIST OF TABLES ................................................................................................................. TOC-2

LIST OF FIGURES................................................................................................................ TOC-3

1. INTRODUCTION ..................................................................................................................1

2. CONTACT LIST ....................................................................................................................3

3. BACKGROUND: KANSAS CITY, MO AND STORMWATER .........................................4

4. STORMWATER MANAGEMENT PROGRAM COMPONENTS ......................................8

4.1 Address Post-Construction Discharge from Areas of New Development and

Significant Redevelopment ............................................................................................ 8

4.2 Control Discharge from Roadways.............................................................................. 17

4.3 Assess Impact of Flood Control Projects on Water Quality Conditions...................... 26

4.4 Control Pollutants in Runoff from Municipal Waste Management Facilities.............. 33

4.5 Monitor and Control Pollutants from Industrial and High-Risk Runoff ...................... 35

4.6 Reduce the Discharge of Pesticides, Herbicides, and Fertilizers ................................. 40

4.7 Reduce Illicit Discharges, Spills, and Improper Disposal............................................ 43

4.8 Reduce Pollutants in Construction Site Runoff ........................................................... 54

5. STORMWATER PUBLIC EDUCATION AND AWARENESS PROGRAM....................58

6. WATERSHED MONITORING PROGRAM.......................................................................63

7. OTHER PERMIT REPORTING REQUIREMENTS...........................................................70

7.1 Summary of Implementation Status............................................................................. 70

7.2 Proposed Changes........................................................................................................ 71

7.3 Program Effectiveness Evaluation Regarding Water Quality Improvement ............... 72

7.4 Data Summary.............................................................................................................. 75

7.5 Annual Expenditures.................................................................................................... 75

7.6 Activity Summaries – Inspection, Enforcement, and Public Education ...................... 78

7.7 Water Quality Degradation / Improvements ................................................................ 80

8. FUTURE IMPLEMENTATION ..........................................................................................81

ATTACHMENTS ..........................................................................................................................82

A-1 Inventory of High-Risk Runoff Dischargers................................................................ 82

A-2 Stormwater Runoff Monitoring: Sampling Plan, and Quality Assurance Project Plan

(QAPP)......................................................................................................................... 82




LIST OF TABLES

Table 1. Recently completed watershed master plans that consider water quality issues .......... 9

Table 2. Summary of tasks associated with addressing post-construction discharge from new

development and significant redevelopment.............................................................. 12

Table 3. Technical and project support for water quality consideration in development planning

and implementation processes ................................................................................... 13

Table 4. Street sweeping data for FY 04/05 .............................................................................. 22

Table 5. Levee maintenance for 2004 ....................................................................................... 24

Table 6. Flood control project tasks .......................................................................................... 27

Table 7. Summary of industrial and high-risk runoff program ................................................. 36

Table 8. Developing an inventory of high-risk runoff dischargers ........................................... 38

Table 9. Solid waste management and recycling services......................................................... 44

Table 10. Performance measures on recent achievements by comprehensive waste management

and Keep Kansas Beautiful........................................................................................ 49

Table 11. Performance of limiting infiltration from municipal sanitary sewers for FY 04/05.... 53

Table 12. Stormwater public education program activities in FY 04/05..................................... 61

Table 13. Watershed monitoring – major program elements and timeframe for the Permit term 68

Table 14. Watershed monitoring – summary of current work progress ....................................... 68

Table 15. Background information for the monitoring stations ................................................... 69

Table 16. Overall budget for programs/activities supporting stormwater management effort in FY

04/05 .......................................................................................................................... 77

Table 17. Activity summary – inspection, enforcement, and public education ........................... 79




LIST OF FIGURES

Figure 1. A scheme of stormwater-related features in the GIS database of Water

Services Department.................................................................................................. 20

Figure 2. Monthly Record of Storm Sewer Structures Maintenance for FY 2004/05............... 23

Figure 3. Record of requests on catch basin/inlets through newly-opened catch basin

hotline........................................................................................................................ 23

Figure 4. Levee System ............................................................................................................. 30

Figure 5. Blue River downstream.............................................................................................. 31

Figure 6. Material by type received at the Household Hazardous Waste Facility during

Jan. – Mar. 2005 ....................................................................................................... 50

Figure 7. Percentage distribution of material treated by Household Hazardous Waste

Facility in 2004 ......................................................................................................... 50

Figure 8. Sites of illegal dumping successfully prosecuted during 2000-2005. ........................ 51

Figure 9. Neighborhood cleanup event and community recycling drop-off site ....................... 52

Figure 10. Stormwater sampling locations.................................................................................. 65

Figure 11. Field sampling equipment......................................................................................... 67

Figure 12. 2000 – 2005 Keep Kansas City Beautiful Program record....................................... 73

Figure 13. 1997 – 2005 Regional Household Hazardous Waste Collection Program –

Quarterly comparison .............................................................................................. 73

Figure 14. 1998-2004 Illegal dumping prosecution result by Environmental Crime Unit.......... 74

Figure 15. 1999-2005 Machine Sweeping Program record ........................................................ 74

Figure 16. 1997-2005 city-wide catch basin replacement program record ................................. 75



Final 1 12/22/05

1. INTRODUCTION

Pursuant to the Federal Water Pollution Control Act, under the authority granted to the State of

Missouri and in compliance with the Missouri Clean Water Law, the Missouri Department of

Natural Resources issued State Operating Permit No. MO-0130516 to the City of Kansas City to

discharge from the Municipal Separate Storm Sewer System (MS4). The permit was issued

effective September 3, 2004 and covers a period of five years through September 2, 2009. The

terms and conditions of the permit require the City to prepare and submit an Annual Report no

later than six months following the period covered by the report. The period covered by the

Annual Report should coincide with the fiscal year, from May 1st through April 30th, and is due

by December 31st each year. This first report covers the partial permit year from the effective date

of the permit September 3, 2004 through the end of the fiscal year April 30, 2005. The next report

will cover the full year from May 1, 2005 through April 30, 2006 and be due on December 31,

2006.

The Stormwater Utility Division of the Kansas City, MO Water Services Department (WSD)

coordinated the preparation and compilation of relevant information into the system-wide Annual

Report. Contributing municipal departments included City Planning and Development, Codes

Administration, Environmental Management, Neighborhood and Community Services, Parks and

Recreation, Public Works, and Water Services. The report also incorporated constructive input

from Black & Veatch Corp. and Limno-Tech, Inc.

This report consists of seven sections:

1. Background: Kansas City, MO and Stormwater. This section provides an overview of the

nature of urban stormwater runoff and the City’s efforts to address stormwater pollution

issues. It also presents landmarks that the City has achieved in stormwater management

from 1990 to the present.

2. Stormwater Management Program Components: Elements of the City’s stormwater

management program are summarized in this section. Measurable goals, objectives,

program development methods, implementation status, and major achievements are

reviewed.



Final 2 12/22/05

3. Public Education Program: Public education is required in multiple stormwater

management programs in the City’s MS4 permit. This section discusses education

activities, currently conducted or planned pursuant to Permit requirements.

4. Watershed Monitoring Program: Monitoring water quality is a critical component in

evaluating the effectiveness of MS4 permit implementation. This section presents a

summary of various on-going monitoring efforts in accordance with the Permit.

5. Other Permit Reporting Requirements: The City’s MS4 Permit requires mandatory

reporting elements that allow for the evaluation of Permit implementation but are not

specifically included in any of the previous sections. These elements include proposed

changes to permit conditions, enforcement actions, and identification of water quality

improvement or degradation, and fiscal analysis.

6. Future Implementation: This section discusses the future direction of stormwater

management in the City.

7. Attachments: A-1 is the Inventory that has been developed for High-Risk Runoff

Dischargers. A-2 provides the Stormwater Runoff Sampling Plan and Quality assurance

Project Plan (QAPP).



Final 3 12/22/05

2. CONTACT LIST

Name and Title Telephone E-mail

Franklyn W. Pogge, P.E. (816) 513-0271 [email protected]

Director, Water Services Department

James W. Mellem, P.E. (816) 513-0368 [email protected]

Assistant Director, Water Services Department

Richard Gaskin, P.E. (816) 513-0352 [email protected]

Manager, Stormwater Utility Division


Jing Tao, Ph.D. (816) 513-0371 [email protected]

MS4 Program Coordinator, Stormwater Utility Division


Former Program Administrators:

Ruth W. Turner, P.E. (816) 513-0363 [email protected]

Former Section Head, Stormwater Utility Division

Manager, Facility Engineering Division (Current)


Ali M. Almai, P.E. (Retired)

Former Manager, Stormwater Utility Division




Final 4 12/22/05

3. BACKGROUND: KANSAS CITY, MO AND STORMWATER

The nature, source, extent and impact of stormwater pollution have been well documented by

numerous scientific investigations and the practical experiences of many municipalities. The

interactions between human activities and stormwater runoff have been a major issue in urban

environments throughout the nation.

Located along the Missouri River, the City of Kansas City, MO (hereafter referred to as the City)

has a population of 441,600 and a land area of approximately 317 square miles. The City

boundary encompasses, in part or whole, more than 35 watersheds. Approximately eighty percent

of the City is served by the separate storm sewer system while the remaining part has a combined

sewer system. From mitigating flooding to preserving stream water quality while sustaining urban

development, it is recognized that managing stormwater has long been a tremendous challenge

for the City. In the early 1990s, the City initiated a systematic stormwater management approach

which focuses on flooding issues. As nationwide and local knowledge and experience on

stormwater issues has accrued over the years, the City’s approach to stormwater management has

evolved into a holistic style, which envisions a sustainable development managed with a sound

environment protection strategy. The following highlights signify major landmarks that the City

has achieved in stormwater management from 1990 to the present:

� 1990: The Department of Public Works initiated the Stormwater Master Plans Study for

35 individual watersheds in the City. Since the late 1990s, this responsibility has been

delegated to the Water Services Department (WSD). The primary purpose of the master

plans, in the past, was to provide a prioritized listing of recommended major capital

improvements to mitigate flooding with a minimal stormwater quality assessment. With

an emerging national concern and increasing regulation of stormwater quality, the City

has gradually included stormwater quality as an important component of the planning

process by incorporating water quality modeling, Best Management Practices (BMPs)

considerations, and stormwater quality monitoring into the watershed master plans.

� 1992:

1. The Stormwater Utility for the City was established by Ordinance No. 920349.

Its mission is “Effectively administering the City’s stormwater management

programs through an overall strategy that maximizes available resources for the



Final 5 12/22/05

protection of lives, property and environment while sustaining economic

development”. The Utility’s major functions are: administration, regulatory

compliance, development review, water resources planning, floodplain

management, environmental planning, capital improvements, and operation and

maintenance.

2. The stormwater user fee was implemented by ordinance, along with the creation

of the Stormwater Utility Division. The revenue from the fee is used for the sole

purpose of stormwater management which includes storm sewer system

maintenance, flood protection system management and stormwater master

planning. The fee structure was revised by ordinance in 1999, to be based on the

amount of runoff surface on each parcel of land in the City.

� 2000: The City, in conjunction with neighboring communities, and Corps of Engineers-

Kansas City District, started a feasibility investigation of the Missouri River and Kansas

River levee systems. The feasibility report is currently being finalized. The findings will

provide an evaluation of the level of protection for the existing levee system, along with

recommendation for improvements.

� 2002: The Stormwater Coordinating Committee (SWCC) was created to facilitate

review and coordination of stormwater management functions for the City. The SWCC

consists of Directors of seven City Departments, which share responsibility for

stormwater management, by (1) reviewing major planning and major development

projects; (2) making recommendation of stormwater policy changes; (3) providing

assistance to the WSD – Stormwater Utility as requested; (4) development of appropriate

stormwater design standards, regulations, zoning and enforcement criteria; and (5)

fulfilling other responsibilities as assigned by the City Manager.

� 2003: The City embarked on the KC-One, City-Wide Comprehensive Storm Water

Management Plan in an effort to integrate the 35 watershed master plans into one

consistent product that establishes stormwater policies and priorities city-wide, and to

enhance its stormwater management. The project envisions a holistic watershed planning,

operating, and growth strategy. Phase 1 of the project established the vision, principles,

and priorities for stormwater management in the City. Phase 2 of the project, currently

under way, will provide a comprehensive plan for stormwater management. The six

major elements to be addressed in the plan include: Policies, Administration, Public

Relations, Integrated Watershed Master Planning, Funding, and Implementation.



Final 6 12/22/05

� 2004:

1. A Wet Weather Solutions Committee was formed to further address the wet

weather needs of the City. The Committee coordinates planning processes

primarily for three wet-weather-related programs – Kansas City Overflow

Control, Stormwater Management, and Waterways. Through the program, the

City aims to accomplish the following: (1) Protect people from loss of life and

injury and habitable property from damage due to flooding; (2) Reduce sewer

overflows; (3) Improve water quality; and (4) Generate multiple benefits such as

natural resource conservation, recreational opportunities, economic investment

and enhanced quality of life.

2. The City authorized a total of $11.2 Million for a city-wide General Obligation

(GO) Bond Catch Basin Replacement program. A total of approximately 5,000

catch basins were slated for replacement within two years. The Notice to Proceed

for the first phase of catch basin replacements was issued in the fall of 2004.

Aproximately $4.4 million of the $11.2 million authorized was bid and under

contract during this reporting period.

On September 3, 2004, the Missouri Department of Natural Resources issued State Operating

Permit No. MO-0130516 to the City to discharge from the MS4. The permit requires the City to

develop and implement nine specific stormwater management programs:

1. Address Post-Construction Discharge from Areas of New Development and Significant

Redevelopment

2. Control Discharge from Roadways

3. Assess Impact of Flood Control Projects on Water Quality Conditions

4. Control Pollutants in Runoff from Municipal Waste Management Facilities not Permitted

by Separate Permit

5. Monitor and Control Pollutants from Industrial and High-Risk Runoff

6. Reduce Discharge of Pesticides, Herbicides, and Fertilizers

7. Reduce Illicit Discharges, Spills, and Improper Disposal

8. Reduce Pollutants in Construction Site Runoff, and

9. Water Quality and Biological monitoring



Final 7 12/22/05

In addition to these programs defined by the permit, the City also considers public education and

awareness, and program funding as two additional important elements to promote the effective

implementation of the permit.

The WSD is responsible for the overall management of the Permit. A project management model

with a team-based approach has been utilized for administration and coordination of each

program. Approximately 40 staff from 7 city departments were identified and assigned for direct

participation in the development of the various program elements. Each team consists of

approximately 6 cross-department representatives. All the teams, except the Funding team, met

on a regular schedule, recorded meeting minutes, and updated their progress to the MS4 Permit

Coordinator. The teams also received support from consultants in the various aspects of the MS4

program, including Black & Veatch and Limno-Tech, Inc. Funding issues have been addressed in

monthly Stormwater Committee Coordinating Meetings. The following sections review the

progress achieved by each team through April of 2005.



Final 8 12/22/05

4. STORMWATER MANAGEMENT PROGRAM COMPONENTS

4.1 Address Post-Construction Discharge from Areas of New Development and

Significant Redevelopment

Background

The City is managing stormwater including understanding its impact, protecting resources, and

incorporating water quality issues into development and redevelopment planning and

management. The City has recognized that a watershed-based decision-making strategy is the

most appropriate holistic approach to managing stormwater quantity and quality. The City is

committed to sustainable development that is healthy and balanced for its economic and

community growth while protecting water quality resources. The following paragraphs provide an

overview of the effort.

– Watershed Master Plan Projects

With an emerging national concern and increasing regulations addressing stormwater quality, the

City’s Watershed Master Plan projects have gradually included stormwater quality as an

important component of the planning process by incorporating water quality modeling, Best

Management Practices (BMPs) considerations, and stormwater quality monitoring into the

watershed master plans. The City’s Watershed Planning Procedures Manual (2000) explicitly

requires “Improvement Identification” from each master plan and describes that “Improvements

to the conveyance system may include, … regional detention facilities, site-specific detention

facilities, …”, and that “Floodplain modifications and improvements may include, … stream

buffers … erosion and sediment controls …”. The manual also points out the need for water

quality modeling. These requirements have been fulfilled in recently completed master plans

(Table 1). Most importantly, the master plans are becoming a practical and useful tool to

development planners and stormwater project managers.

– City-wide Comprehensive Stormwater Master Plan: KC-ONE

As individual watershed master plans were completed, the City saw a need to bring these plans,

reflecting diverse opinions and procedures, into a cohesive, consistent product that defines



Final 9 12/22/05

Table 1. Recently completed watershed master plans that consider water quality issues A

Watershed Completion Date

Water Quality Modeling

BMPs Recom-mendation

Stormwater Quality Monitoring

Round Grove Creek

Little Shoal Creek

Walnut Creek

Second Creek

Upper Shoal Creek

Line Creek

Mill Creek

Turkey Creek

April, 2002

April, 2002

October, 2002

June, 2003

June, 2003

December, 2003

March, 2004

October, 2004

+

+

+

+

+

+

+

+

+

+

+

+

+

+

+

+

Brush Creek (north)

Northeast Industrial District (Phase 3)

Rush Creek

Todd Creek

Birmingham Creek

Draft under review B





+

+

+

+

+

+

+

+

+

+

Buckeye Creek

Rock Creek

Randolph Creek

Searcy Creek

In draft B

In draft B

In draft B

In draft B

+

+

+

+

+

+

+

+

+

+

+

+

A The remaining watersheds were accomplished prior to 2002.

B Applies to the status in FY 2004/05.

priorities city-wide. In 2003, the City began the two-phase KC-One project. Phase One

established the vision, principles, and priorities for stormwater management in the City. These

elements would guide the development of the scope of work, budget, and schedule for Phase

Two. KC-One sees stormwater management as a holistic watershed planning, operating, and

growth strategy. It focuses on developing municipal policies that support, encourage, and require

“green” multi-purpose flood control and conservation, resource protection and stormwater

management.

– Kansas City, Missouri Stream Asset Inventory Projects



Final 10 12/22/05

Since 2002, the City Planning and Development Department, with the help of Patti Banks

Associates, has been developing a stream asset inventory. Such a natural resource inventory is

intended to provide a foundation for future growth and development, as well as resource

conservation efforts. The first two phases of the Stream Asset Inventory Projects were finished

between 2002 and 2004. Assessments were performed for seven watersheds including: Line

Creek, Round Grove, Fishing River, Second Creek, East Fork Shoal Creek, Little Shoal Creek,

and Shoal Creek. The assessment process consists of field reconnaissance, stream bank and

streambed characterization, erosion characterization, measurement of flow rate, vegetation

identification, field survey of aquatic communities, site photographs, and general observations of

stream conditions. The Phase I project report has been completed. The Phase II report is currently

being drafted, and will enhance the City’s ability to incorporate stream resources into the

planning process for better stormwater quality management, flood prevention, stream protection,

and healthier communities.

– American Public Works Association (APWA) Section 5600 Storm Drainage Systems

and Facilities Manual, and Manual of Best Management Practices (BMPs) for

Stormwater Quality

Both manuals are the result of collaborative efforts among the Mid-America Regional Council

(MARC), the Kansas City Chapter of American Public Works Association, and local

municipalities, including the City. They were approved and adopted in 2003 at a regional level,

and are available from the link http://www.kcapwa.net/specifications.asp. APWA 5600 was

developed to provide regional standards and guidance for storm drainage system design and

performance, and stream preservation in the Metropolitan Kansas City area. The BMP manual

provides guidance for planning and implementing BMPs applicable to this region. The City is

planning to adopt it.

– Detention basins

The City’s policy regarding detention facilities has been one of private-ownership and private

maintenance, authorized by Maintenance Agreement between the developers and the City’s

Public Works Department. However, the City is granted right of access for maintenance at the

developer’s expense, if the developer fails to perform appropriate maintenance.



Final 11 12/22/05

The WSD developed a suite of Detention Basin Credit procedures to encourage the use of

detention BMPs in 2001. The procedures provide a credit (up to 50%) on the stormwater

impervious surface user fees for certified detention basins or ponds. To determine if certification

requirements are met, City staff conducts formal inspections of detention facilities. The certified

basins are also logged into the department’s geographic information system (GIS) database

referencing stormwater structures.

Program Objectives

• To reduce the discharge of pollutants to the MS4 from areas of new development and

significant redevelopment after construction is completed,

• To encourage sustainable development through environment-friendly planning and

design and effective operation and maintenance of BMPs,

• To assure effective operation and maintenance of BMPs.

To fulfill these objectives, multiple tasks have been established, and the City is tracking

their completion. These activities and their status are described in Table 2.

Discussion

1. Including water quality considerations for areas Permit Ref. III.A-1a. of new development and significant redevelopment Status: Ongoing

The existing programs as described above reflect the City’s initiatives to recognize and treat

water quality issues as early as practical in the development planning process, and as late as

possible in the post-development phases (“cradle-to-grave process”). The programs (Table 3)

constitute multiple ways water quality is considered in the process of new development and

redevelopment.

While the Stream Asset Inventory provides planners with the resources to consider stream assets

during the City’s planning process, the Stormwater Master Planning Program offers a

preliminary identification of water quality issues, and BMP recommendations for the watersheds

to address water quality and flooding problems. The KC-One Project is developing an integrated



Final 12 12/22/05

Table 2. Summary of tasks associated with addressing post-construction discharge from new development and significant

re-development

Permit

Ref.

Task Sub-task Activities

Status Output

(1) Continue KC-One Project Draft Stakeholder Interview Report for the Kansas City Water Services Department

(2) Continue Kansas City, MO Stream Asset Inventory

Kansas City Stream Asset Inventory Phase I – Tools and Strategies for Protecting Natural Resources

(3) Continue the Stormwater Master Planning Program

Ongoing

Seven watersheds master plans

(4) Adopt the update American Public Works Association (APWA) Section 5600

NA

1a. Incorporate water quality considerations for areas of new development and redevelopment: (1) in land use planning, subdivision approval, and site plan review and approval; and (2) in project review and approval for new development and significant redevelopment

(5) Adopt Manual of Best Management Practices (BMPs) for Stormwater Quality

Ongoing

NA

(1) Critically evaluate the existing permitting procedure

1a.i & ii

Improve procedures for incorporating water quality concerns as part of the permitting process

(2) Modify it to address water quality issues appropriately

Ongoing NA

1a.ii. Upgrade the site development review standards Ongoing APWA Section 5600

1a.ii. Internal and external education on review standards and process

• 8 staff meetings

• 30 Stakeholder interviews

• 2 Workshops and 1 presentation for planning and other internal staff trainings

Ongoing NA

1a.iii. Set up minimum design criteria for structural BMPs Ongoing Manual of Best Management Practices (BMPs) for Storm-water Quality

(1) I/M public detention BMPs • 8 Inspections 1b. Inspect and maintain (I/M) post-construction BMPs (2) I/M private detention BMPs • 11 Inspections

Ongoing Nine private BMPs were newly approved to receive credit.



Final 13 12/22/05

Table 3. Technical and project support for water quality consideration in development planning and implementation processes

Supporting

functions

Manuals/ Projects Salient features Focus Status Current practice

Policy

Strategic

Resources

Technical

Standards

Enforce-

ment

KC-ONE Project Stream Asset Inventory The Stormwater Master Planning Program American Public Works Association (APWA) Section 5600 (Revised) Manual of Best Management Practices (BMPs) for Stormwater Quality Covenant for Main-tenance Agreement Detention Basin Credit Program

- Will develop a City-wide comprehensive stormwater management plan - Will investigate control of storm water through protection, restoration, and maintenance of natural streams - Will minimize impacts of development by implementing smart growth principles, sustainable development, and BMPs - Provides tools and strategies to incorporate protection, enhancement, and management of stream resources into the City’s planning process - Identify stormwater-related water quality problems based on field observations and modeling results for each watershed - Provides elevated design criteria and performance standards for storm drainage systems - Adds Section 5605 of Natural Streams which sets forth requirements for stream preservation and buffer zones - Provides guidance for land development practices within the region - Includes performance-based goals and design criteria to facilitate “Level of Service Method” objectives - Ensure the maintenance responsibility of detention BMPs - Provide incentives for detention BMPs use - Ensure the effectiveness of detention BMPs

Water quantity /quality Water quality Water quantity Water quantity Water quality Water quantity

Ongoing Ongoing (Phase I completed in Dec., 2003) Ongoing Ongoing Ongoing Ongoing

Not available Used in the City’s land use decision making and development planning The same as above Pending for adoption Pending for adoption Active Active



Final 14 12/22/05

approach that provides the City direction on the best way to implement stormwater infrastructure

improvements, including community participation. The Detention Facility Credit Procedures

were developed to provide an incentive to developers and private residences to properly install

and maintain BMPs, allowing the City to ensure the effectiveness of BMPs post-development.

The technical references that support this program include APWA Section 5600 Storm Drainage

Systems and Facilities, and Manual of BMPs for Stormwater Quality.

Through the KC One Stormwater Master Plan Project, the city is continuing its stream asset

inventory process. In FY 04/05, the City proceeded with stream asset inventories for the

remaining 28 watersheds not yet addressed within municipal boundaries. By the end of FY04/05,

three additional watersheds – Indian Creek, Dykes Branch, and Town Fork Creek – had field-

assessments completed. Additionally, a stormwater "green filter" analysis has been conducted on

the East Fork of Line Creek sub-watershed. The purpose of the green filter analysis is to identify

suitable locations for possible implementation of natural or “green” Best Management Practices

(BMPs) that could be used to reduce and/or eliminate some of the major capital improvement

projects previously recommended through individual stormwater studies. Assessments of

additional watersheds are ongoing and may be followed up by further green filter analyses and

BMPs recommendation.

2. Procedures for addressing water quality issues Permit Ref.: III.A-1.a.i. as part of the permitting process Status: Ongoing The team implementing this program is critically evaluating and improving the City’s current

permitting procedures for new development and significant redevelopment. The distinctive

features for the modified procedure will include requesting a “Macro Stormwater Drainage

(MaSD) Study” to be submitted at the time an application is made for a development proposal; a

performance-based evaluation of BMPs, and a Performance and Maintenance Bond [financial

assurance instrument (FAI)] to ensure future maintenance.

The City is currently developing BMP inspection, performance, and maintenance standards, and

will revise standard agreements to reflect owner responsibility of maintenance and performance

of BMPs for construction and post-construction periods.



Final 15 12/22/05

3. A description of review standards and a description Permit Ref.: III.A-1.a.ii. of the site development review process for Status: Ongoing internal and external education purposes

The City plans to adopt the APWA 5600 developed by the Kansas City Metropolitan Chapter of

APWA in November 2003, as the new review standards. Compared to the current standards, the

latest one contains: (1) elevated design criteria and performance standards for storm drainage

systems (e.g., it requires the release rate from a detention facility after construction be no more

than what existed predevelopment for the full range of storms); and (2) new requirements for the

protection of natural streams as a conveyance for stormwater, and the establishment of buffer

zones. Different approaches to stream preservation and different standards for buffer widths

depending on basin size are also elaborated on further in the manual.

4. Design criteria for structural BMPs Permit Ref.: III.A-1.a.iii Status: Ongoing The Manual of Best Management Practices (BMPs) for Stormwater Quality co-developed by the

Mid-America Regional Council (MARC), the Kansas City Chapter of APWA, and local

municipalities is considered as minimum design criteria manual for BMPs. The City is working

toward officially adopting this manual. The manual lists 12 types of structural BMPs and

provides information on design criteria and plan/profile views, along with selection, maintenance,

and advantages and limitations for each BMP. In addition, the manual offers more detailed

guidance for several widely used BMPs (e.g., bioretention basins, engineering swales).

5. Operation and maintenance of post-construction BMPs Permit Ref.: III.A-1.b. Status: Ongoing

The City currently does not own or maintain any regional detention basins. In 1997, the City’s

MS4 permit application referenced eight detentions basins. Inspections of the eight basins were

performed in 2004. Upon recent verification, it was determined that only five of these are public

detention basins, but not at a scale that qualifies them as regional basins. The basin at 1200 E

Linwood is owned and maintained by the City’s Board of Police. The basins in Kessler Park and

Strathbury Park are maintained by the Parks and Recreation Department. The department is

currently seeking multi-use options for the Kessler Park basin. The basins at 8801 James A Reed

Road and Kensington Road are owned and maintained by the WSD.



Final 16 12/22/05

The use of regional detention basins to assist the City with MS4 compliance is being investigated.

Part of this investigation includes the preparation of a stream asset inventory, as mentioned

above. A maintenance program for regional detention basins, as required to be reported by the

Permit will be established as part of the design process for the basins.

During the reporting period, additional inspections were conducted at 11 private residences, nine

of which were granted the Detention Facility Credit. A total of 58 private detention BMPs have

received credit thus far.

Next Steps

The City is currently drafting ordinance language authorizing the adoption of the technical

manuals [the updated APWA 5600 and the Manual of Best Management Practices (BMPs) for

Stormwater Quality] and will submit it to the City Council for consideration and adoption before

the end of FY06.

Educating the City planners and other staff on the updated review standard, as well as the

development of educational plans for developers, homeowners, and businesses, are currently

underway (Table 3).

The Covenant for Maintenance Agreement between the City and BMP owners/operators will be

revised to enforce the maintenance, repair, and retrofit of BMPs. Additionally, the use of regional

detention BMPs is recommended for new development plans. For such BMPs, the City is

developing BMP inspection performance and maintenance standards, and considering public

ownership and public maintenance responsibility as a more effective approach to maintenance.



Final 17 12/22/05

4.2 Control Discharge from Roadways

Background

The City has been and continues to actively operate and maintain deicing chemical and material

storage facilities, as well as publicly-owned streets, roads, and highways in a manner that

coincides with the requirements set forth by the MS4 Permit.

– Snow and ice control

Due to its geographic location, Kansas City is subject to various winter weather extremes.

Climatic changes make it possible to receive snow, ice, and/or freezing precipitation any time

from November through the end of April. The City has a network of roughly 900 miles of arterial

and primary streets, which must be plowed and/or salted during winter storm events. The system

includes another 1,500 miles of residential roadways, which also need to be plowed during these

same events.

In September 2003, the City adopted its Public Works Winter Storm Manual to provide policy

and procedural guidelines for the Snow and Ice Control Program. The roadway system is divided

into 40 routes, with 145 deicing and snow removal vehicles shared among the Parks and

Recreation Department, Water Services Department, and Public Works Department. Snow and

ice control operation procedures, staff responsibilities, training requirement, and reporting

procedures are described in the Manual. The usage of salt, salt and calcium chloride mixtures,

salt/abrasive, liquid calcium chloride, or salt brine depends on specific conditions as specified in

the Manual. Salt application follows the guidelines from The Snow Fighters Handbook published

by the Salt Institute. In general, the City is using a policy of Sensible Salting, which emphasizes

getting the most out of every application of deicing salt and maintaining the safe roads in an

economical way while protecting the environment. The key elements in the policy include

personnel training, good equipment, calibration of spreaders, use of automatic controls, adequate

covered storage, proper maintenance, an awareness of safeguarding the environment, and timing

of rock salt application.

– Street maintenance



Final 18 12/22/05

The City Public Works Department runs two street maintenance programs. The Machine

Sweeping Program covers three different street systems: main arterial streets, downtown streets,

and residential streets, totaling 252 routes, and 3,942 gutter miles/cycle. The program includes

schedules and descriptions for each street system. The program schedule is updated annually and

its performance is recorded by the Public Works Department. The department also has an Adopt-

A-Street program to generate public awareness of ways to improve the appearance of public

rights-of-way as well as to facilitate public involvement.

The City’s Parks & Recreation Department maintains 12.67 miles of the park system’s interior

roads and hundreds of its parking lots under the Park Road Sweeping Program. It holds an annual

sweeping event following July 4. The department also provides debris removal services as

needed, and has contractors to remove limbs in the public right-of-way of boulevards after

extreme storm events.

In addition to the direct maintenance of public streets, the City’s Solid Waste Division (formerly

in the Department of Environmental Management, now in the Department of Public Works) runs

Leaves and Brush Collection services to assist street maintenance. The Leaves and Brush

Collection program provides residences both curbside collections twice a year as well as two

drop-off sites free for city residents to use year round.

– Stormwater structure maintenance

The City conducts routine inspection, repair, and replacement of inlets and sewer lines, regular

maintenance of levees, and channels, and on-call services. The WSD has a division of 45

individuals devoted to stormwater maintenance. There are approximately 34,000 inlets and catch

basins throughout the City. Inlet inspection and cleaning is performed on a two-year cycle, with

approximately 17,000 inlets and catch basins maintained each year. The City conducts a routine

storm sewer inlet repair and replacement program on an ongoing basis. The City completes

approximately 210 repair work orders a year and replaces approximately 100 inlets each year.

In addition, the City conducts an annual catch basin replacement program. Over the last couple of

years, approximately 400 catch basins have been replaced per year. A study was performed in



Final 19 12/22/05

2001 which indicated that there was a backlog of approximately 1,700 catch basins identified for

replacements and an additional 3,500 identified for repairs.

The Stormwater Utility Division of WSD operates and maintains more than 13 miles of levees

and floodwalls on the Missouri and Blue Rivers. Activities include regular inspections, repairs as

needed, vegetation management, review of construction activities near the levee, and operation

during high water and flood threat conditions. In addition to the City’s levee system, there are

also levees protecting Kansas City, KS; North Kansas City and Birmingham, MO. A joint project

is currently underway with these cities to assess the overall flood protection level and determine

if modifications are needed to any portion of the system to improve its effectiveness from a

metro-wide perspective.

– Geographic information system (GIS) for stormwater structures

The City Information Technology Department manages spatial data for the City. It has a

geographic information system for the City’s land base information. The base map dataset is

comprised of base, planimetric, address, and centerline/intersection categories, and covers over

170,000 parcels, 5,500 plats, 240 neighborhoods, 125,000 street segments, and 34,000 street

intersections. Supported by this central source of base map data, the WSD is implementing

multiple GIS applications that will allow its staff to access stormwater information through an

ArcGIS interface.

The GIS databases associated with stormwater systems consist of point (e.g., catch basin, curb

inlet), line (e.g. culvert), and poly- (e.g., watershed boundary, impervious surface) features

(Figure 1). The data sources include existing asbuilt sets and field investigations. The department

is developing and maintaining these GIS databases to manage its program of repair/replacement

and maintenance of storm sewer system component assets. It also has developed a stormwater

map system to support storm water billing.



Final 20 12/22/05

Figure 1. A scheme of stormwater-related features in the GIS database of Water Services

Department

swFlowMetersPoint swInletPoint swDischargePoint

• Catchbasin • CurbInlet • DropInlet • setbackCurbInlet • FieldInlet • TrenchDrain

• swLevee

• swHydrologyLine

C. Poly- Feature

A. Point Feature

B. Line Feature

swCulvert

sw_PolygonFeature sw_PolylineFeature sw_PointFeature

• swStopLogGap • swJacksonFloodingPoint • swFloodBarricade • swFloodAlarm

• swSampleLocationsPoint

• swWatershedBoundary

• swRainGaugeLocationsArea

• swRasterGridArea • swCSSProjectArea • swCSSStudyArea • swSSSProjectArea • swRetiredImpSurf

• swImpSurface

• swParcelBoundary • swCatchmentArea



Final 21 12/22/05

Program Objectives

The objective of this program is to continue the City’s effort to operate and maintain public

roadways and storm sewer systems in a manner that reduces the pollutant input from the MS4

into receiving waters. The current key targets include improving the efficiency of stormwater

structure maintenance and replacement, timely updating stormwater structure information in the

WSD’s GIS database, and further developing the mapping system to be more user-friendly.

Discussion

1. Store and cover deicing chemicals to minimize Permit Ref. III.A-2a. the discharge of deicing salts to the MS4 Status: Ongoing

The City Public Works Department has deicing chemical and material storage facilities at each of

its four districts. The facilities vary in size and capacities ranging from 6 to 12 thousand tons of

materials. Rock salt is stored in dome structures. The domes are constructed on asphalt slabs and

consist of wooden and concrete structural materials, capable of containing deicing chemicals

during periods of extended storage. Salt brine and calcium chloride are used as major deicing

agents for the public streets. They are stored in tanks. Potassium acetate is employed only on the

Chouteau Bridge. It is stored in a metal tote.

The Parks and Recreation Department stores approximately 200 tons of rock salt at its own

facility for emergency use. This is a covered bin facility built on concrete slab base.

2. Effectively sweep public streets while considering Permit Ref. III.A.2b. water quality and watershed goals and objectives Status: Ongoing

Table 4 provides performance measurements for our street sweeping program for the fiscal year

of 2004/05. The program currently uses Elgin Eagles for road speed, and the mechanical brooms

perform better than the vacuums collecting the type of dust on local streets.



Final 22 12/22/05

Table 4. Street sweeping data for FY 04/05

Actual Street system Route Gutter

Miles/

Cycle Total

(miles)

Debris removed

(cubic yard)

Residential

Arterial /Boulevards

Downtown

Total

232

18

2

252

3,532

368

42

3,952

12,268

2,355

3,065

17,688

22,929

2,285

858

26,072

In the past fiscal year, the City Parks & Recreation Department continued to maintain its 212

parks, interior roads, and hundreds of parking lots. It also provided debris removal service as

needed, and had contractors remove limbs in the public rights-of-way after storm events.

During the past fiscal year, 28 new volunteer groups joined the City’s

Adopt-A-Street program and 71 more blocks were adopted, totaling 175

active volunteer groups throughout the City, and over 600 blocks adopted.

The Leaves and Brush Program collected approximately 2,500 tons of

yard waste at its two drop-off center for FY 04/05, and approximately

1,500 tons of yard waste during its curbside collection in the fall of 2004.

3. Storm sewer maintenance Permit Ref. III.A.2c Status: Ongoing For FY 2004/05, the Stormwater Maintenance group accomplished 15,937 cleanings or

inspections and 184 repairs of catch basin/inlets (Figure 2). Note that this work is season-

dependent.

To ensure better response and service to the residents, in January, 2005, the City established a

catch basin hotline (816-513-0500), through which residents may request maintenance for curb

inlets and catch basins that are clogged, damaged, flooding or need to be cleaned. From January

to April, 2005, there were 235 requests for service (Figure 3). These requests were logged in the

system, prioritized, and sent to maintenance crews, inspectors and engineers for follow-up

actions.



Final 23 12/22/05

0

400

800

1200

1600

2000

2400

May

June

July

Aug.

Sept.

Oct.

Nov.

Dec.Ja

n.Feb

.M

ar.

Apr.

FY 2004/05

Catc

h b

asin

/Inle

t cle

aned/inspecte

d

0

5

10

15

20

25

30

Catc

h b

asin

repaired

Catch basin/inlet

cleaned/inspected

Catch basin/inlet

repaired

Figure 2. Monthly Record of Storm Sewer Structures Maintenance for FY 2004/05

Figure 3. Record of requests on catch basin/inlets through newly-opened catch basin

hotline

0

20

40

60

80

100

120

February March April

2005

Num

ber

Replacement

Flooding

Cleaning

Total

Types of call



Final 24 12/22/05

To enhance the proper function of stormwater structures, the City kicked off a General

Obligation (GO) Bond-funded Catch Basin Replacement Program in December, 2004. The

program is designed to eliminate the backlog of catch basins that need to be replaced. The City

has awarded five catch basin replacement contracts with private contractors to replace

approximately 2,000-catch basins city-wide at a total cost of approximately $ 11.2 million. The

work under these contracts is scheduled for completion in early 2006.

Regular maintenance of the levees including mowing, and removing litter and debris, was

performed (Table 5). Herbicide was applied by certified technicians where needed.

Table 5. Levee maintenance for 2004

Actual for 2004

3 times per year

Levee maintenance (mowing/removing debris/herbicide use as needed)

Length (ft) Area (acre)

Total length (ft)

Total area (acre)

Missouri River 39,100 92.26 117,330 276.78

Blue River Channel 9,400 48.9 28,200 146.7

For the fifteenth consecutive year, the City’s Parks & Recreation Department, through a

partnership with the departments of Environmental Management and Water Services, other

regional/local agencies, and organizations has continued to provide in-kind support for the

cleanup of Blue River, a tributary to the Missouri River. The support includes providing facility,

equipment, and expertise, and assistance with program coordination. More than 500 volunteers

participated in this event in April, 2005. Over fifty tons of trash, including abandoned cars,

appliance, and tires were removed from the river riparian areas. Hundreds of tree seedlings were

planted along riparian areas to help reduce erosion.

4. GIS mapping of the storm sewer systems Permit Ref. NA Status: Ongoing

The current focus of the GIS mapping effort for stormwater issues includes:

� Continuing to develop and update the database with the information supplied by field

inspection crew, engineering as-built drawings from construction projects, and latest

photometric products;



Final 25 12/22/05

� Incorporating the new data from the City-wide Catch basin Replacement Program into

the database;

� Unifying and systemizing stormwater data produced by the Watershed Master Plan

studies; and

� Transferring data from GeoMedia and MicroStation work platform to ESRI ArcGIS.

Next Steps

The three key permit requirements are currently being implemented. The City plans to fine tune

the existing program by improving documentation, which will increase our ability to measure

performance.



Final 26 12/22/05

4.3 Assess Impact of Flood Control Projects on Water Quality Conditions

Background

The City has been working cooperatively with the US Army Corps of Engineers for many years

on several large-scale flood-control projects in Kansas City: Blue River Channel, Dodson

Industrial District, and the Swope Park Industrial Area all along the Blue River; Brush Creek

from the State Line to the Blue River; Turkey Creek with its waterway in Kansas, but causing

flooding in Missouri; and Seven Levees along the Kansas and Missouri Rivers. Additionally,

there is one regional detention basin that exists in the Kansas City area, Longview Lake. This

basin is located in the Little Blue River watershed in south Kansas City. It was constructed and is

maintained by the US Army Corps of Engineers. These projects have all been in the planning,

design, construction and/or operation and maintenance phases for more than ten years, and are

considered to be existing projects for purposes of this report. New flood control projects are being

considered as part of the City’s stormwater master planning efforts addressed in Section 4.1 of

this report.

At the beginning of the flood control program performed in cooperation with the US Army Corps

of Engineers, the City’s primary responsibilities consisted of land, easement, and right-of-way

acquisitions necessary for the project; resident and business relocations; and utility, roadway and

bridge modification or relocation. The focus of the City’s efforts and the majority of expense

were in acquiring the property necessary for the US Army Corps of Engineers to design and build

the flood control projects. Since 1980, the City has expended approximately $45 million on flood

control acquisitions through administration of the Flood Control Program by the Special Projects

group of the Public Works Department, which was transferred into the Water Services

Department as the Waterways Division in 2004. The acquired properties are mostly located

within the Blue River Watershed and were acquired for the Blue River Channel, Dodson

Industrial District and Brush Creek flood control projects. The properties were mostly flood-

prone, under-utilized properties through the industrial corridor in eastern Kansas City, Missouri.

Work has progressed significantly on each of these flood control projects with approximately

$250 Million in construction having been completed. These projects have evolved from having a

focus on flood damage reduction to helping water quality efforts through restoration of riparian

corridors, improved wildlife habitats, green space buffers, and recreational components.



Final 27 12/22/05

The Permit requires that the City describe and implement procedures to assure that existing and

new flood control projects be assessed for impacts on the water quality of receiving water bodies

through two distinct steps. Initially a process is to be developed to evaluate water quality

improvement aspects of existing and new flood control projects. This will be followed by the

actual evaluation of existing flood control projects for retrofitting with storm water quality

controls, and by submission of a list of flood control facilities utilized for water quality

improvement. The process developed in step one is addressed in this first report. The retrofit

evaluation and identification of projects is to be reported on in subsequent years.

Program Objectives

The objectives of this program are to assure that existing and new flood control projects are

assessed for water quality impacts. Existing facilities are to be evaluated for retrofitting by

enhancing structures with water quality features based upon considerations of type, location,

watershed, ownership, public health, benefits and cost. New projects are to be evaluated using

developed assessment procedures. Tasks were identified for the first two permit years (Table 6).

Table 6. Flood control project tasks

Permit

Ref.

Task Sub-task Status

Identify flood control projects A.3a & b Define “flood control project”

Identify scope of projects to be included

Completed

Evaluate existing flood control projects for water quality retrofitting

Initiated

A.3b. Obtain a determination of water quality considerations typically associated with flood control projects

Evaluate new flood control projects, incorporating water quality consideration into the planning and design phases.

Initiated

Discussion

1. Identify flood control projects Permit Ref. III.A-3a & b Status: Completed



Final 28 12/22/05

To obtain an appropriate evaluation of water quality improvements to existing and new flood

control projects, a clear and accurate understanding of the definition of “flood control project” is

important. According to the team’s communication with MDNR, “flood control projects” are

interpreted as: “Normally …referring to storm basins, small ‘storage lakes’, and other projects

(wetlands creation for example) that would store potential flood waters. It could also include

projects that store floodwaters in-channel or within the floodway.”

Using this definition the team identified existing flood control projects and their scopes. Because

of the long-term and large scale, along with the interdependency of the many sub-projects

comprising these flood control projects, both ongoing and completed flood control projects are

considered as existing for the purposes of this report. Seven existing flood control projects were

identified. The project with a brief scope is provided below:

� Blue River Channel Improvement – This project was authorized by Congress in 1970.

The US Army Corps of Engineers and the City have worked together on the Blue River

project since 1979. Construction began in 1983 and the current anticipated completion

date is 2010 (based on availability of federal funding). The project extends from the

mouth of the Missouri River upstream for approximately 12 river miles. The major

elements of the project are channel deepening and widening (substantially complete),

road and railroad bridge modifications and replacements (ongoing), roadway and utility

relocations, and construction of a levee/berm and grade control structure (designed). The

project also has a plan (partially implemented) to mitigate for damages to the

environment, and mitigation efforts will continue as the project progresses.

� Dodson Industrial District Levee/Floodwall - This project was authorized by Congress in

the 1996 Water Resources and Development Act (WRDA). It consists of over a mile of

levee/floodwall and gate systems along the north-west bank of the Blue River from the

Bannister Federal complex to Bruce R. Watkins Drive to provide a 500-year flood level

protection to the Dodson Industrial District. Phase 1 of the project was completed in

October 2004, and Phase II is scheduled to be completed in FY 2006. The remaining

phases will be scheduled based on the available federal and local funding.



Final 29 12/22/05

� Swope Park Industrial Park Levee/Floodwall – The plan for this project has been

developed by the US Army Corps of Engineers and approved by the Chief of Engineers.

It is now awaiting authorization in the next WRDA. The project area is located within the

100-year flood plain of the Blue River, much of it within the floodway resulting in

especially hazardous flooding conditions along the only ingress/egress to the park. The

project will consist of a levee/floodwall providing a 100-year level of protection.

� Brush Creek – This is a flood damage reduction and beautification project extending

from State Line on the west to Blue River on the east, approximately 6 miles in length.

The Prospect Avenue Bridge project was completed in October of 2004, and the Brush

Creek channel improvements in the Prospect and Woodland reaches are underway and

nearing completion. The US Army Corps of Engineers, the Federal Emergency

Management Agency, and the City all contributed to this $14 million dollar bridge and

channel project. Design is underway on the Troost at Brush Creek project, which will

connect the flood control channel improvements near the Country Club Plaza to those

downstream. Additional work is being planned to connect those channel improvements in

the Plaza upstream to flood control efforts that have taken place at the Rockwell Bridge.

� Turkey Creek Flood Mitigation Project – This is a flood mitigation project involving the

US Army Corps of Engineers; the Unified Government of Wyandotte County, Kansas

and Kansas City, Kansas; and Kansas City, Missouri. The watershed is located largely

within Kansas, and the waterway is located entirely within Kansas. However, when the

creek floods its banks most of the damage is experienced in Kansas City, Missouri. The

project was authorized by Congress in 1999 and construction is underway on the tunnel

rehabilitation. Other elements of the project are in the design phase. The project includes

channel improvements, rehabilitation of the Turkey Creek tunnel that flows into the

Kansas River, a levee/berm, and bridge replacements.

� Levee Systems: The City’s levee system consists of a series of earthen levees,

floodwalls, flood pumping stations, relief wells, toe drains and slope protection along

portions of the Missouri River and the Blue River. The entire Kansas City, Missouri levee

system is divided into three portions named Central Industrial District (CID) Unit, East



Final 30 12/22/05

Bottoms Unit and North Kansas City Unit (Figure 4). The City is working with the Corps

of Engineers and other levee operators along the Kansas and Missouri Rivers in the

Kansas City area on a Feasibility Study to evaluate the levees and develop appropriate

plans to assure they function as intended.

Figure 4. Levee System

� Longview Lake – This lake is the only regional detention basin that exists in the Kansas

City area. This basin is located in the Little Blue River watershed in south Kansas City.

It was constructed and is maintained by the US Army Corps of Engineers.

2. Evaluate existing flood control projects for Permit Ref. III.5A.3b water quality retrofitting Status: Initiated

The above-mentioned seven projects are currently considered for ways in which to incorporate

water quality improvements. As these projects were designed and then constructed for managing



Final 31 12/22/05

flood water quantity, incorporating water quality treatment as required by the Permit presents

both an opportunity and challenge to the City.

The three Blue River projects are all being performed in cooperation with the Corps of Engineers,

and authority exists in that basin to re-evaluate the projects. A general reevaluation has begun and

will include looking for opportunities to improve water quality, primarily through modification of

the constructed portions of the project by creating wetlands and restoring habitat. There are some

features that have already been installed in various reaches of the Blue River channel project that

emulate a natural stream (Figure 5). Native grasses and other special grass mixtures that support

wildlife are planted along the bank of the river to provide an environmentally friendly channel

and to help filter out some pollutants that are mixed in the runoff going to the channel.

Riprap installed in 1999 Greened bank in 2005

Figure 5. Blue River

For Brush Creek a new authority was recently acquired from Congress to allow for a basin-wide

approach to a study that in part will consider water quality. The City and Johnson County, Kansas

have entered into an agreement with the US Army Corps of Engineers to accomplish this

Feasibility Study, which also looks at recreation along the creek and the associated water quality

improvements appropriate to meet those needs. The project management plans for the execution

of these efforts are under development and will further define the processes by which water

quality will be addressed. These Blue River and Brush Creek evaluation and study efforts are the

means by which to evaluate water quality improvements on a watershed basis, in cooperation



Final 32 12/22/05

with other stakeholders, and to engage the public in discussion. For various reasons the remaining

projects offer very limited opportunity for retrofit.

3. Evaluate new flood control projects Permit Ref. III.5A.3b Status: Initiated

The staff will start to evaluate new flood control projects. A regional detention basin is planned to

be added to the Line Creek watershed as a part of flood control in northern Kansas City. Newly

constructed regional detention facilities will address water quality in their designs.

Next Steps

The staff from the Stormwater Utility Division and Waterways Division will participate with the

Corps of Engineers in the planning, design, and construction to assure that appropriate water

quality improvements are incorporated into existing flood control projects where feasible.



Final 33 12/22/05

4.4 Control Pollutants in Runoff from Municipal Waste Management Facilities

Background

There are no active municipal waste landfills in the City. Municipal waste generated in Kansas

City, MO is hauled directly to landfills outside the City limits. Six sites in the City are known to

have operated as Municipal Waste Landfills in the past. These include 97th Street Landfill, 87th

Street Landfill, Round Grove Creek Landfill, Heart Landfill, Milwaukee Landfill, and Riverfront

Landfill. These landfills have been closed for more than 30 years. They are covered with soil and

have no designed impervious cap or liner. Currently, thick bush and patches of trees occupy the

top of these landfills.

City staff from the Department of Environmental Management, now called the Office of

Environmental Quality, performs a walk-through inspection for each landfill on an annual basis.

The purposes of these inspections are to ensure that the landfills remain undisturbed, the covers

remain intact, and that there are no visible indications of harm to human health or the

environment.

Program Objectives

The Permit does not require actions for the first two permit years. Nevertheless, the City will

continue its annual landfill inspections. In addition, realizing that it is in the City’s best interest to

protect its surface water quality, the City has started to work on the monitoring requirements for

the subsequent permit years.

Discussion

1. Continue annual landfill inspection Permit Ref. III.A.4 Status: Ongoing

Inspections were conducted at the 97th St., 87th St., Round Grove Creek, and Heart Landfills.

Active leachate seeps were observed, and initial characterization of these seeps was performed.

Follow-up monitoring was conducted as described in the next part.



Final 34 12/22/05

2. Monitor pollutants in runoff from the landfills Permit Ref. NA Status: Ongoing Preliminary sampling and analysis were performed on the seepages from the 87th St. and 97th St.

landfills by City staff. The samples were analyzed for more than 130 parameters including

biochemical oxygen demand (BOD-5day), metals (7 analytes), volatile organic compounds (65

analytes), and semi-volatile organic compounds (64 analytes). The analysis was performed by

Severn Trent Laboratory at University Park, IL, using applicable EPA methods. The analytical

results did not indicate any obvious adverse impact. The need for additional monitoring will be

considered and a sampling plan will be made as necessary.

Next steps

The following activities are planned for subsequent permit years:

• Inspect the six landfills

• Develop a Sampling and Analysis Plan to determine the impact of the landfills on

adjacent surface waters.

• Begin implementation of the Sampling and Analysis Plan.

Kansas City, MO Preliminary Report


Final 35 12/22/05

4.5 Monitor and Control Pollutants from Industrial and High-Risk Runoff

Background

A number of industrial and commercial facilities are operating within the City boundary, many of

which are located within the City’s MS4 area. Currently, approximately 30 facilities within the

City have Missouri State Operating Permits and nearly 80 facilities have State Stormwater

Permits. Identification of those facilities requiring a state stormwater permit is based primarily on

SIC code. Additionally, the City maintains a list of approximately 70 Significant Industrial Users

in association with the industrial wastewater pretreatment program. Given the potential

contribution of pollutants by industrial users to both the sanitary sewer and storm sewer systems,

the City is addressing pollutant contributions from these facilities in a more comprehensive

manner. The City is developing a program to target facilities for further evaluation and/or

monitoring. Parallel to this effort, the City is working on its ordinance to ensure adequate

authority to perform the tasks associated with the stormwater permit and to protect stormwater

quality.

Program Objectives

The following objectives were established for the first permit year:

• Create the inventory of industrial facilities that have high-risk runoff discharging to the

MS4

• Establish a priority list of high-risk runoff facilities

• Develop an inspection or self-auditing program

To fulfill these objectives, multiple tasks have been established, and specific activities have been

completed. These activities are described in Table 7.



Final 36 12/22/05

Table 7. Summary of industrial and high-risk runoff program

Permit

Ref.

Task Sub-task Activities Status Output

(1) Compile a list of Hazardous Waste Treatment, Storage, and Disposal facilities, and Resource Recovery facilities;

Attachment 1

(2) Determine criteria for selecting other high-risk runoff dischargers;

Table 8

5a. 1. Create an inventory of potentially significant dischargers

(3) Compile a list of other high-risk runoff dischargers.

Completed

Attachment 1

(1) Determine criteria for selecting priority facilities;

NA 5b. 2. Create a priority list of high-risk runoff dischargers (2) Derive a priority list of high-risk runoff

dischargers.

Ongoing

NA

(1) GIS layers/map showing: locations of the Inventory facilities; the Combined Sewer System/Separate Storm Sewer System areas; streams and watershed boundary;

3. Build a GIS database of high-risk runoff dischargers

(2) GIS layers attributed with the information from the Inventory or the Priority list.

Completed GIS layers/map

(1) Set up inspection procedures;

(2) Determine inspection priority, frequency, and methods for record keeping and updating;

NA 5c. 4. Develop an inspection program for high-risk runoff dischargers

(3) Set up inspection checklist with user instruction.

� 20 weekly meetings (4-5 City employees/ 1 consultant/MS4 staff from Independence City);

� 4 facility visits/inspections;

� Communicating with MDNR experts, and MS4 staff from other cities;

� Research on federal and state regulations;

� Research on other cities’ development or implementation of MS4 high-risk runoff program, and their pertinent ordinances.

Ongoing

NA



Final 37 12/22/05

Discussion:

1. Create Inventory of Potentially Significant Dischargers Permit Ref. III.A.5a Status: Complete

The purpose of building an inventory is to identify and assess both existing and potential

significant stormwater pollution sources. Table 8 provides a general overview of the methodology

used in developing the Inventory. Given the limited information about the City’s industrial and

commercial facilities, three additional categories were targeted and screened in the first Permit

term. Table 8 identifies those categories of facilities included in the inventory, as well as selection

criteria.

In total, the Inventory lists 129 facilities: 37 municipal facilities and 92 private sector facilities

(Attachment 1). Included in the Inventory are ranking (rank 10 being the greatest risk), facility

name, activity address, watershed, storm sewer system type, and contacts where available.

2. Establish Priority List of High-Risk Dischargers Permit Ref. III.A.5b Status: Ongoing

The purpose of deriving a priority list is to focus monitoring efforts on those facilities that have a

high potential to impair water quality. Since the information on stormwater pollutant loadings

from the facilities in the inventory is scarce, a ranking system was designed to derive the priority

list. The ranking system will be further tested and used to prioritize the inventory list. A

description of the system and the priority list will be detailed in the next report.

Of note, the inventory was compiled from several data sources and the coming priority list will

derive from the Inventory. The details about individual facilities as described in these documents

will be verified and updated during facility inspections. The City views both the inventory and

priority list as living documents that will be developed further as a result of any additional

information collected by the City. The criteria used to develop these two lists shall not be

considered as a constraint to exclude other facilities from being listed. Any facility, upon

being identified as posing a high potential for stormwater pollution, will be included in the

documents where appropriate. Any addition or removal will be justified and documented.



Final 38 12/22/05

Table 8. Developing an inventory of high-risk runoff dischargers

Permit

Requirement

Data Source Major Criteria Other Criteria # of Facilities

Selected

Total # of Facilities in

the Inventory (after

Consolidation)

5.a.i Missouri Department of Natural Resources (MDNR)

Hazardous waste Treatment, Storage, Disposal (TSD); Resource Recovery (RR) facilities;

11

5.a.ii MDNR Toxic Release Inventory (TRI)

1. In active operation now or within the past year;

2. Not in RCRA closure corrective action

42

MDNR Large Quantity hazardous waste generators (LQG)

36

Mid-American Regional Council (MARC)

Emergency Planning and Community Right-to-know Act TIER II list

48

Kansas City-Water Services Department

Significant Industrial Users (categorical facilities or SIU)

1. The type of industrial activity;

2. The likelihood that storm water discharge from the site will be contaminated;

3. Location: Combined Sewer System area or Separate Storm Sewer System area

4. Professional judgment.

32

5.a.iii

Kansas City-Department of Environmental Management

Municipal Facilities 1. Primary activities 2. The likelihood that storm

water discharge from the site will be contaminated;

3. Professional judgment.

37

129



Final 39 12/22/05

3. Develop an inspection Program Permit Ref. III.A.5c Status: Ongoing

An inspection program targeting industrial facilities has been developed. The purpose of the

program is to prevent, control, reduce, and minimize the pollutants from high-risk runoff

facilities. The program establishes inspection objectives, defines its scopes, and provides a set of

inspection procedures, schedule, and inspection checklist with user instruction. A detailed

description of the program will be provided in the next report as required.

4. GIS Mapping Permit Ref. NA Status: Complete

Though not required by the Permit, the City has initiated a GIS database for the facilities in the

inventory and priority list. The database includes data layers of facility locations, the City

Combined Sewer System (CSS) and MS4 boundary, separate sewer system components (lines,

outfalls, catch basins, inlets, etc.), streams and watershed boundaries, and updated aerial photos,

parcel boundary, and contour lines. The relevant attributes are also part of the database. It is

believed that such a database will be a useful tool for data display, analysis, and retrieval. More

importantly, the database has proven useful for facility inspection planning.

Next Steps

The City will continue its current efforts to target high-risk-runoff facilities. Additionally, the

City is starting to educate municipal employees about stormwater pollution prevention, and will

launch stormwater inspections for municipal facilities. An industrial facility stormwater runoff

monitoring program will be developed.



Final 40 12/22/05

4.6 Reduce the Discharge of Pesticides, Herbicides, and Fertilizers

Background

The permit requires the City to implement a program to reduce pollutants in discharges from the

MS4 associated with pesticides, herbicides, and fertilizers. An evaluation of the City’s ongoing

efforts was conducted by representatives from the following departments: Water Services, Public

Works, Environmental Management, Neighborhood Services, and Parks and Recreation.

Substantial ongoing activities have been identified which provide a solid foundation upon which

to build enhanced levels of effectiveness.

Program Objectives

The objective of this program is to eliminate the unnecessary or improper use of pesticides and

herbicides through controlled management of city operations and training for staff and through

educational efforts aimed at the broader public.

Discussion

1. Continuing the public education program Permit Ref.: III.A.6.a to promote the proper use, handling, storage, and Status: Ongoing disposal of PHFs

The City has provided public educational and awareness materials on the City’s website,

including a webpage dedicated to pesticides and fertilizers which can be found under the header

page, Earth Matters – Gardening and Landscaping. The site addresses some of the negative

impacts of improper use of pesticides, herbicides and fertilizers and encourages the public to use

more natural ways to eliminate pests and to fertilize gardens and lawns. The document

emphasizes reading and following the manufacturer directions when using pesticides, herbicides,

and fertilizers, highlighting the message – More Is Not Better.

The City operates an award-winning household hazardous waste (HHW) disposal program.

Initiated in 1996, the City facility provides the hub for a cooperative regional collection system

for the Missouri portion of the metropolitan area. Residents may bring most types of household



Final 41 12/22/05

hazardous wastes, including pesticides, herbicides, and fertilizers, to the facility for proper

disposal. Mobile events also are held throughout the City and the region to provide convenient

opportunities for disposal. The program provides a viable alternative to improper disposal in

solid waste, storm sewer, or sanitary sewer facilities. Public education is a significant component

of the program and provides a significant opportunity for enhancing public awareness.

2. Implementing BMPs to reduce the contribution Permit Ref.: III.A.6.b of pollutants associated with the application, storage, Status: Ongoing and disposal of PHFs on city-owned property and right-of-ways

The City’s Environmental Management System (EMS) assures that City employees, through each

individual’s training plan, are familiar with the appropriate use of hazardous chemicals including

pesticides, herbicides, and fertilizers. Implemented in February 2000 by an Administrative

Regulation, the EMS provides a comprehensive approach to assure that City activities are

conducted in an environmentally responsible manner.

The City Manager has assigned each Department Director the responsibility for assuring that

activities performed by his or her Department are performed in an environmentally appropriate

manner. The City has developed an Environmental Training Plan for every employee, identifying

the specific training needed to prepare each employee for his or her duties and responsibilities.

Employees who work with or in close proximity to hazardous chemicals (such as PHFs) take a

Hazard Communication class. The Hazard Communication class teaches about the hazards of

various chemicals, the precautions to take when using hazardous chemicals, what to do in the

event of an emergency, and how to find and understand the Material Safety Data Sheet for each

chemical encountered in the work place.

Employees who are responsible for responding to incidents involving hazardous chemicals or

who might be the first person to discover a spill take the appropriate level of hazardous waste

operations and emergency response training. This training teaches procedures and techniques to

address spills, fires, and other chemical emergencies safely and effectively.



Final 42 12/22/05

Employees who work with restricted use pesticides receive the Certified Pesticide Applicator

training, which covers the proper handling, application techniques, application rates, and safety

precautions for working with pesticides.

Every City facility receives an annual environmental audit, which includes a review of procedures

to acquire, store, use and dispose of hazardous chemicals. Any “opportunities for improvement”

identified by the auditor are included in the written audit report and tracked to ensure timely

implementation. In addition, each facility performs environmental self-inspections on a daily,

weekly, or monthly basis (depending on the number of environmentally significant activities at

the facility) to detect and correct deficiencies, including any problems related to hazardous

chemicals.

Next Steps

The City is in the process of completing the KC-One Project which is a comprehensive

stormwater management analysis for the entire city. Results of this planning effort will include

policies and procedures for addressing stormwater management issues in the city. Substantial

educational opportunities will result from the process and will provide valuable venues for

disseminating appropriate information on pesticide/herbicide management. In particular, the City

wants to focus on the potential for working through landscape/greenhouse retail and related

establishments to foster a cooperative relationship that supports safe and proper management of

these products. One of the City’s annual environmental improvement goals for FY04/05 and

FY05/06 is to increase the use of xeriscaping and native plantings to reduce the use of water,

chemicals, and mowing on City owned land. The City has a workgroup meeting to focus on the

issue.



Final 43 12/22/05

4.7 Reduce Illicit Discharges, Spills, and Improper Disposal

Background

–Solid waste management and recycling services

To minimize improper disposal, the City provides comprehensive solid waste management and

recycling services at the curb and at drop-off sites (See Table 9). Most of the services and

programs listed in Table 9 were established in the 1990s. Some of them have continued to grow

and evolve into new programs. An example is the Neighborhood Cleanup Assistance Program

(NCAP), established in 1997. Its initial purpose was to provide affordable dumpsters to

neighborhood organizations wanting to maintain their neighborhoods. It has evolved, over the

past three years, to include the organization of neighborhoods and other groups willing to assist in

the cleanup of vacant lots, problematic and blighted neighborhoods, and other common areas

(those frequently-complained of by residents). The program has also developed a strong

partnership between the City, neighborhoods, state, private volunteers, institutions, business, and

other organizations interested in building beautiful, clean, and safe communities.

These waste management efforts support the mission of the stormwater management program in

the following ways: (1) promoting the efficient operation and maintenance of stormwater

structures (e.g., inlets, outfalls) by preventing litter, leaves and brush from entering the storm

sewer system; (2) reducing and removing potential pollutant sources by providing services for

toxic household waste disposal, by collecting leaves and brush, and by organizing neighborhood

cleanups; and (3) raising the public environmental awareness by involving residents’ participation

and changing their trash disposal practices.

– Household Hazardous Waste Management Program

The City’s Household Hazardous Waste Management Program accepts, manages, and recycles or

safely disposes excess or unwanted household chemicals from residents, as well as hazardous

materials from city facilities. The program comprises three major components: a Household

Hazardous Waste (HHW) Facility, a Swap Shop, and mobile HHW collection events. The HHW

facility opened in September 1996. The facility was initially planned to process 425,000 pounds

of material annually. This number was surpassed in 1998, and the facility now processes close to



Final 44 12/22/05

Table 9. Solid waste management and recycling services

Services/Programs Curbside Drop-off sites Neighborhood

Trash collection

KC Recycles

Drop-off recycling

Bulky item collection

Leaves & brush collection

Drop-off L&B collection

Providing dumpsters

Neighborhood cleanup

Tire drop-off

Household hazardous waste management

Swap shop

Once a week

Every other week

-

Monthly/bi-monthly

Once in the spring, once in the fall

-

-

-

-

-

-

-

4 sites, 4 days/week

-

2 sites, 1 day/week

-

-

1 site, 1 day/month, March thru November

1 center, 3 days/week

same

-

-

-

-

-

Upon request

Priority areas

Combined with neighborhood cleanup

Mobile services for neighboring cities/counties

same

1 million pounds per year. The Swap Shop offers reusable products from people who no longer

need them to other residents who do. Products typically available at the shop include: household

paint, automotive paint, oil, antifreeze, spray paint, fertilizers and miscellaneous items. Mobile

HHW collection events are operated by a crew of trained city personnel. Volunteers from the

neighborhood or community in which the collection is taking place help with traffic control and

record-keeping. The Mobile HHW collection events serve over 35 cities in five counties.

Materials collected at HHW mobile events are recycled or disposed of through one of the city’s

hazardous materials contractors. Materials that are in good condition are offered back to the

community through the Swap Shop. In addition to providing HHW collection service, the City’s

HHW Management Program works closely with Missouri Department of Natural Resources,

Environment Protection Agency, Public Safety, and Homeland Security on various issues as

needed, and provided assistance in developing the Missouri Safe Schools CD.



Final 45 12/22/05

– Keep Kansas City Beautiful

Over the past five years, the City has undertaken another significant effort: sponsoring the Keep

Kansas City Beautiful Program, run by the non-profit organization – Bridging the Gap, a Keep

America Beautiful affiliate since 2000. The Keep Kansas City Beautiful Program focuses on litter

abatement through grassroots outreach and community involvement. Under this program, various

activities have been organized, including Litter-free events, Adopt-A-Spot program, the annual

Great American Cleanup, Kansas City area litter index measurement, and environmental

education speakers training. This program provides important support to the City’s stormwater

management program by reducing potential pollutant sources for stormwater runoff and through

outreach to communities and cultivating grassroots involvement.

– Illegal dumping investigation

The City created the Environmental Crimes Unit (ECU) in 1998. The unit had been run by the

Department of Environmental Management until the end of FY 2004/05. This enforcement

function has since been transferred to the Neighborhood & Community Services Department. The

ECU served as a clearinghouse for reports of crimes against the environment, such as illegal

dumping, and refers the crimes to the appropriate agency for investigation and possible

prosecution. A conviction on municipal charges could result in up to 12 months' imprisonment

and/or a fine up to $1,000. The unit also keeps track of previous illegal dumping sites and

conducts a trend analysis to identify the positive impact from Litter Abatement in the Keep

Kansas City Beautiful Program.

– Spill response

The Hazardous Materials Division (HazMat 71) of the City’s Fire Department responds to and

controls hazardous materials releases. The division consists of 25 trained staff, including a

division chief, a chemist, and a training/equipment officer. The division is equipped with various



Final 46 12/22/05

types of mobile detection equipment for measuring, identifying and verifying releases of

hazardous chemicals. The division has adopted a general operating guideline – HazMat Response

for First Responders, which also addresses different approaches to spills or leaks of various types

of chemicals/materials (e.g., flammable liquids, oxidizers and organic peroxide). These guidelines

specify keeping spilled material and contacted runoff out of any sewer and water systems. The

HazMat Division works closely with other city departments and outside agencies and contractors

for subsequent cleanup.

– Sanitary sewer system maintenance

In light of issues with the aging infrastructure and evaluating sewer system capacity for new

development projects, the WSD performs various activities to prevent infiltration from municipal

sanitary sewers into MS4. The activities include: (1) televising the City’s sewer system, which

helps evaluate and make the necessary repairs and improvement; (2) performing necessary

cleanups through high CFM vacuuming or other methods; and (3) rehabilitating and/or replacing

manholes and sewer lines. The City also responds to emergency sewer line repair. The WSD is

developing a long-term separate sewer system control plan to further reduce infiltration and

inflow. The plan will be completed in 2008.

Program Objectives

• Develop a city ordinance to prohibit illicit discharges to the waters of the MS4 except for

certain listed de minimus discharges. The City will develop a procedure for investigation of

illicit discharges and enforcement to prevent such discharges.

• Identify priority areas for illicit discharge screening, including concentrated areas of

industrial and commercial facilities, and develop procedures for conducting field screening

activities and recording results.

• Continue to implement procedures to investigate when illicit discharges are discovered or

reported.

• Continue to implement procedures to prevent, contain and respond to spills that may

discharge into the MS4.

• Continue public education program to inform the public on how to respond to spills, illegal

dumping, illicit discharges, and water quality problems.



Final 47 12/22/05

• Continue use of the mobile collection events or establish collection sites for household

hazardous waste.

• Continue sanitary sewer maintenance program to limit infiltration from municipal sanitary

sewers to the MS4.

Discussion

1. Develop a city ordinance to prohibit illicit Permit Ref. III.7.a. discharges to MS4 Status: Ongoing

The permit requires the City to develop an ordinance to prohibit illicit discharges to the MS4.

The definition and development of the required ordinance is underway and is scheduled for

review in the spring of 2006. The ordinance proposed by the WSD will be submitted to the City

Council for their consideration before the end of the fiscal year (April, 2006).

2. Develop a procedure for illicit discharge Permit Ref. III.7.a & d investigation and enforcement Status: Ongoing The City is using EPA’s Investigation of Inappropriate Pollutant Entries into Storm Drainage

Systems, January 1993, as the governing standard for illicit discharge investigation. The

procedure is still in development.

3. Identify priority areas and develop Permit Ref. III.7.b procedures for field screening activities Status: Ongoing

The team is developing maps to be utilized for identifying the areas to target for illicit discharge

investigations. A map has been developed outlining the MS4 area. The City’s Sewer Atlas has

also been used to identify the existing storm sewer outfalls. Zoning maps have been reviewed to

identify the industrial areas. The outfall information along with the zoning maps will be used to

create maps for field screening. The team has also worked with WSD – Industrial Waste Division

and the Environmental Management Department to identify risk areas from records based on

industry type and previous problem areas. The EPA’s “Illicit Discharge Detection and

Elimination”

4. Prevent illicit discharge and improper disposal Permit Ref. III.7.d & f Status: Ongoing



Final 48 12/22/05

The City has continued implementing various waste management programs. Table 10 provides

performance indicators on its recent achievements. In addition to this progress, the following

items are of particular note:

1. The waste collected by different programs is recycled, reused, and treated through

various methods including composting of yard waste, and burning tires as fuel by

Missouri cement factories.

2. In 2004, the Household Hazardous Waste Management Program serviced 7,922 drive-up

vehicles and collected 1,188,206 pound of waste (ninety percent of which was hazardous,

Figure 6). The program’s mobile outreach events serviced 3,341 households, 18 cities,

and 5 counties. The collected waste was recycled, swapped, waste/energy recovered, or

processed through other methods by city staff. The Swap Shop housed in the Household

Hazardous Waste Facility provided over 125,000 pound of material to the public for its

intended use and kept it out of landfills. In the first quarter of 2005, approximately

124,200 pounds of waste (see Figure 7) was collected. The City’s HHW Management

Program has recently been awarded by the U.S. Environmental Protection Agency for its

successful implementation of an Environmental Management System (ISO 14000).

3. The Environmental Crimes Unit (ECU) successfully prosecuted 58 individuals for illegal

dumping. Figure 8 shows the illegal dumping sites that were reported in the past five

years. The map helps staff evaluate the impact from other programs (e.g. Keep Kansas

City Beautiful – Litter abatement), and prioritize target areas for field screening.

4. While implementing various waste management programs is a primary task, public

education and grassroots outreach have been conducted. Staff working on these programs

takes the opportunity to deliver educational messages to the public wherever possible.

This effort will be described further in the next section of this report, Stormwater Public

Education and Awareness.



Final 49 12/22/05

Table 10. Performance measures on recent achievements by comprehensive waste

management and Keep Kansas City Beautiful

Community Recycling (FY 04/05)

A KC Recycles (FY 04/05)

Materials recovered (ton) Cars Bridging the Gap volunteers Materials recovered (ton)

3,316 150,638 2,094 11,203

Tire Drop-off (Mar. – Oct. 2004)

Number of tires collected at drop-off site Number of tires collected during Neighborhood Cleanup events

4,089 6,259

Appliance and Bulky Items (FY 04/05)

Number of appliance collected Bulky items collected (ton)

4,403 21,030

Leaves and Brush Collection (FY 04/05)

Homes served Drop-off site (ton) Curbside (Fall, 2004) (ton)

138,763 2,500 1,500

Illegal dumping (FY 04/05)

Illegal dumping prosecuted cases Illegal dumping cleanup (ton)

58 3,357.8

Neighborhood Cleanup Assistance (Mar. 2004 – Oct. 2004)

Providing dumpsters to qualified neighborhoods Neighborhood cleanup

Number of events (dumpster and

scheduled cleanups)

Number of participating neighborhood associations

Cleanup waste (ton)

Number of events (dumpster and

scheduled cleanups)

Number of participating neighborhood associations

Cleanup waste (ton)

127 107 733 11 49 1,883

Household Hazardous Waste (2004)

HHW Facility Mobile outreach B Swap shop

HHW received (lb)

Number of vehicles delivering HHW

HHW received (lb)

Number of vehicles delivering HHW

Material (lb)

Cost saved ($)

679,297 4,906 389,048 3,780 208,373 96,373

Keep Kansas City Beautiful (FY04/05)

Adopt-A-Spot

Kansas City Metropolitan Area in Great America Cleanup (GAC, March – May 2004) C

Volunteer

Litter free events

attendees Litter (Ton)

Illegal dump-sites

Tires Street (mile)

Park area (acre)

River (mile)

# Hours 23 events/ 125

volunteers 2550 2,235 388 7,019 139 66 21 7,686 32,336

A Data from Kansas City Community Recycling Centers Annual Report 2004-2005. B Served 18 neighboring cities and 5 counties in 2004. C GAC: for metropolitan Kansas City in Great American Cleanup during March, April and May of 2004.



Final 50 12/22/05

Antifreeze

0%Water Reactive

0%Toxic Solids

0%Insecticide Gases,

Flammable.

0%

Toxic Liquid Flammable

Organic (Pestcd)

0%

Flammable Liquid Toxic Organic

(Pestcd)

3%

Latex

32%

Batteries, Automotive

23%

Batteries, Ni-Cad

0%

Flourescent Lighting

Waste

1%

Steel

0%

Sulfuric Acid

0%

Used Oil (Spec used

oil)

0%

Flammable Liquids

6%Used Oil (Non Spec)

0%Acids

1%

Bases

1%

Oxidizers

0%

Batteries, Alkaline.

(Stabilized )

3%

Paint Related Materials

30%

Total weight: 124,200 lb, not including materials collected by mobile events

Figure 6. Material by type received at the Household Hazardous Waste Facility during

Jan. – Mar. 2005

Recycled

25%Waste / Energy

Recovered

25%

Neutralized

2%

Other

20%

Incinerated

4%Swapped

24%

Total weight treated: 1,008,348 lb Figure 7. Percentage distribution of material treated by Household Hazardous Waste

Facility in 2004



Final 51 12/22/05

Figure 8. Sites of illegal dumping successfully prosecuted during 2000-2005.



Final 52 12/22/05

Figure 9. Neighborhood cleanup event and community recycling drop-off site

4. Spill prevention, containment, and response Permit Ref. III.7.e Status: Ongoing The City’s Hazardous Material Division (HazMat 71) responded to 259 spill/leak incidents

between August, 2004 and August, 2005. Approximately 49 percent of the incidents were

attributable to gasoline or other flammable liquid spills, 28 percent of the incidents were

associated with oil or other combustible liquid spills, 14 percent were due to chemical spill, and

the remaining 9 percent were related to flammable gas or liquid condition and refrigeration leak.

The Public Safety section of Information Technology Department keeps track of the spill

incidents that the Hazardous Material Division has responded to. A new record management

system has been implemented, and the system tracks activities on an annual basis (August to

August).

5. Public education Permit Ref. III.7. f Status: Ongoing See Discussion 4.4 of this program and Section 5. Stormwater Public Education and Awareness Program of this report. 6. Continuing the sanitary sewer maintenance program Permit Ref. III.7. g Status: Ongoing See Table 11 for performance details.



Final 53 12/22/05

Next Steps

The outfall survey will be conducted along with the maps identifying the high risk areas. Initial

field screening activities have been planned, and actual field investigations will begin and be

reported. The City continues the development of the procedures to investigate illicit discharges

when discovered or reported. The City also continues to implement procedures to prevent,

contain, and respond to spills that may potentially discharge into the MS4.

Table 11. Performance of limiting infiltration from municipal sanitary sewers for FY 04/05

WSD-Maintenance (estimated)

TV Sanitary sewer lines

Sewer line cleanup Manholes rehabilitated

Sewer line rehabilitated/replaced

73 miles 416 miles 563 9.375 mile (49,500 ft)

Emergency response by WSD-Wastewater Maintenance Division

Public main repairs Public manhole repairs Private main repairs

224 115 275

Emergency response by WSD-Engineering Division (2004)

Public main repairs Private repairs

600 ft. 130



Final 54 12/22/05

4.8 Reduce Pollutants in Construction Site Runoff

Background The City has an established erosion and sediment control program for construction site runoff.

The latest Erosion and Sediment Control Ordinance, Chapter 63, Article II of the Kansas City

Code of Ordinances, Ordinance No. 981135 was passed in 1999. The purpose of the article as

stated:

The purpose of the article is to promote and protect the public interest by

regulating land disturbance, land fill, and soil storage in connection with the clearing and

grading of land for construction-related or other purposes. It is also the purpose of this

article to encourage responsible development and minimize the cost to the development

community as a result of the regulations in this article.

This article establishes administrative, implementation, and enforcement

procedures for the protection and enhancement of the water quality of watercourses,

water bodies, and wetlands by controlling erosion, sedimentation, and related

environmental damage caused by construction-related or other activities.

The ordinance was reviewed by MDNR during the MS4 permit development process and was

found to be acceptable. The permit’s objectives also allow for future modifications to the existing

ordinance after further review by the City.

Program Objectives

• Review and update Erosion and Sediment Control Ordinance, Chapter 63, Article II. The

updated grading ordinance will require implementation of erosion and sediment control

BMPs and other measures during active construction activities.

• Develop and implement an effective system to track erosion and sediment control permits

on active construction sites.

• Inspect active construction sites for compliance with the City’s Erosion and Sediment

Control Ordinance.

• Provide Inspector Training and outreach to the Construction Industry.



Final 55 12/22/05

• Enforce the City’s Construction Site Runoff Program

Discussion

1. Erosion and Sediment Control Ordinance review and update Permit Ref. III.8.a Status: Ongoing

The permit requires the City to continue its program to reduce the discharge of erosion and

sediment pollutants to the MS4 from construction sites disturbing one acre or more. The current

program authority is granted pursuant to the Erosion and Sediment Control Ordinance, Chapter

63, Article II of the Kansas City Code of Ordinances. The City will continue its erosion and

sediment control program.

A review of the Erosion and Sediment Control Ordinance, Chapter 63, Article II has been

completed to provide compliance with the permit. As a result of that review, five changes to the

ordinance are proposed as follows:

� Require site disturbance permits for land disturbances that are less than one acre in size,

but that also are adjacent to or were previously part of a larger development project of

one or more acres.

� Require a cash deposit sufficient for the installation and maintenance of erosion and

sediment control BMPs in lieu of a performance bond.

� Increase the required frequency of field inspections from once every fourteen days to

once every seven days.

� Require the director of Codes Administration to issue a stop work order in accordance

with Chapter 18 of the Code of Ordinances when site disturbance permits are revoked.

� Reduce the duration of time from ten days to one day that a site disturbance permittee is

given to comply after a stop work order is issued.

Specific ordinance language implementing the proposed ordinance changes has been

drafted and submitted for review.

2. Maintaining an inventory of active construction sites Permit Ref. III.8.b Status: Ongoing



Final 56 12/22/05

The City maintains two inventory systems to track land disturbance activities. One system

inventories and tracks construction projects contracted directly by the City. The other system

inventories and tracks site disturbance permits issued by the City. A critical review of the two

inventory systems for possible improvements is underway and will be completed before the end

of the next fiscal year.

3. Inspecting construction Sites Permit Ref. III.8.c Status: Ongoing

The City conducts field inspections for both City construction projects and sites with site

disturbance permits. A review of the field inspection program is underway and is scheduled for

completion before the end of the fiscal year. In the interim, the review proposes that the field

inspection program be conducted on the following frequency:

Site Activity Ground Status Inspection Frequency

Active Not Stabilized Once per week

Active Partially Stabilized Once per two weeks

Inactive Not Stabilized Once per month & after rain event

Inactive Stabilized Once per two months

An Erosion and Sediment Control Inspection Report form was drafted incorporating any

information required by the permit and also any information to provide additional details to

evaluate the erosion and sediment control measures and plan.

4. Providing inspector training and outreach to Permit Ref. III.8.d the construction industry Status: Ongoing

The development of an inspector training program and a construction industry outreach program

is underway and scheduled for completion before the end of the second permit year.

5. Enforcement of the City’s Construction Site Runoff Program Permit Ref. III.8.e Status: Ongoing



Final 57 12/22/05

The City currently enforces its construction site runoff control program. A review of the current

enforcement program is underway and scheduled for completion before the end of the next fiscal

year. Progress on these efforts will be reported.

Next Steps

The recommended modifications to the Erosion and Sediment Control Ordinance discussed

above will be reviewed, and refined as needed by the City’s legal staff. Implementation results

will be reported.

The City will work toward developing a centralized database that covers both private and

municipal construction projects. The team is planning to work with non-governmental agencies

such as Mid-American Regional Council (MARC) or American Public Works Association

(APWA) – Kansas City Chapter to run a training program for field inspectors and the construction

industry. The team will also work with these agencies to finalize the appropriate testing and

certification programs necessary for the inspectors and construction industry.



Final 58 12/22/05

5. STORMWATER PUBLIC EDUCATION AND AWARENESS PROGRAM

Background

Nonpoint source pollutants are ubiquitous, constituting a major contributing factor to stormwater

pollution. Promoting public education and raising awareness of stormwater pollution is a key

component of an effective stormwater program. The City has been working on public stormwater

education mainly through the following means.

– Stormwater website

In the spring of 2003, the City established a website devoted to Stormwater Education and

Involvement. The purpose of the site is to inform residents of ways to help protect streams and

rivers and keep Kansas City's waterways clean. The following topics are addressed:

� Cause and Effect Animation, which illustrates how illegal dumping and new

construction affect water quality and quantity;

� Earth Matters, which elaborates on important stormwater issues, including Erosion

Control (how erosion occurs, how to prevent, etc.), Big No No’s (routine practices that

are harmful to the environment), Scoop the Poop (the importance of cleaning up pet

waste), Landscape and Gardening (addressing pesticide and herbicide application, use

of native plants, and rain gardens), and Environmental Contact Information (phone

numbers for citizen questions).

� Kids Corner, which combines animation, narrative description, and designed exercises

to illustrate the importance and methods of protecting our water resources

� Safety, which informs residents of flooding hazards, and the flood warning system

serving the City.

� Brush Creek Investigation, which presents the result of preliminary research on the

storm water runoff quality in the City.

– Co-sponsoring The Week of Water Festival Annual Event

The City is actively involved in the Week of Water Festival, an annual regional public

educational event that is attended by area school science classes and the general public, in



Final 59 12/22/05

celebration of the federal Clean Water Act (CWA). The City contributes both funding and staff

support to co-sponsoring this annual event. The central themes of the event are encouraging

grassroots efforts, providing community outreach, and promoting water quality education.

– Water Quality Education Brochures

The City has been playing a significant role in a regional effort [led by the Mid-American

Regional Council (MARC), with the cooperation of other municipalities] to design, publish, and

distribute a series of educational brochures. Topics covered in the past have included Use Lawn

Chemicals Wisely, Pick up after Your Pet, Keep Streams Clean, Oil and Water Don’t Mix, and

Wash Your Car the Right Way.

– Water bill inserts program

Water bill inserts entitled as Water Lines are used as informational and educational materials,

delivered with bi-monthly water bills to residents and businesses via U.S. mail. The program

started in late 1990s. There are more than 185,000 customers that receive the inserts on a bi-

monthly base. The primary purpose of the program is to update the general public on

programmatic progress as well as ongoing projects related to the City water services. The inserts

also provide an important mechanism to convey educational messages. Examples of the subjects

addressed in the past have included Facts about Stream Corridors and Installation of Flow

Meters on Town Fork Creek.

– Storm drain stenciling program

The storm drain stenciling program was established in 1996 to make the public aware that

nothing but rainwater should enter storm drains. Its central theme is preventing improper disposal

of materials into storm drains and protecting streams and rivers through public involvement. The

program now involves hundreds of students and scouts.

– Education effort from KC-ONE and Overflow Control (OCP) programs

KC-ONE focuses on stormwater management, and the OCP addresses sanitary sewer overflows

within the CSS and SSS. To serve the need for public education and participation in activities of



Final 60 12/22/05

both programs, an extensive public participation program was initiated. Several new committees,

e.g., Wet Weather Community/Public Panel, were formed consisting of the public and interested

stakeholders, officials from various levels and city departments, and WSD staff. Public meetings

are held to present and discuss the proposed control plan at various locations within the City.

– Other activities

Other activities conducted by the City include holding public watershed education meetings,

bringing stormwater education into high school classrooms, distributing Oil & Grease pollution

prevention door hangars and holding corresponding trainings for food facility owners.

Program Objectives

Stormwater public education is a key element of many of the programs conducted by the City and

required under the MS4 stormwater permit. To facilitate its implementation and to underscore its

significance, the City has extracted the public education requirements throughout the Permit, and

consolidated them into this Stormwater Public Education and Awareness Program. However,

each related program still takes responsibility for any technical training (such as construction

inspector training) and will expect to use this program as a resource.

Discussion

1. Continue and improve existing public Permit Ref.: NA stormwater education programs Status: Ongoing

See Table 12 for various program activities that have been accomplished during the reporting

period. These activities are not only an extension of the previously established programs, which

see stormwater pollution prevention as an important issue, but an improvement of these existing

programs, which makes stormwater pollution prevention a priority.

2. Coordinate with other MS4 programs Permit Ref.: NA Status: Ongoing As the MS4 programs grow over time, additional educational needs will be identified. The



Final 61 12/22/05

Stormwater Public Education and Awareness program will address these needs and provide

necessary resources when public outreach and education is necessary.

Table 12. Stormwater public education program activities in FY 04/05

Program Activities Description

Website development and maintenance Co-sponsoring the Week of Water Festival

Contributing to developing education brochures

Distributing bill inserts Stenciling on storm drains Bringing stormwater education into classroom Educating residents and restaurant owners Public participation in KC-ONE and OCP

Refined the page of Gardening and Landscaping. The theme is cultivating native plant life and composting vs. applying pesticides and fertilizers. Developed new page on “Illicit Discharges” to raise public awareness. Co-sponsored the festival fair by the Missouri River at the City of Parkville on Oct. 8 and 9, 2004; provided water quality/watershed/stormwater education brochures and T-shirts to approximately 1200 attendees (mostly school children and teachers). Contributed to the design and distribution of new brochures, including Storm Drain Stewardship, Making and Using Compost, Keep Sediment out

of Our Waters, and Conserve Water with Rain Barrels. >185,000 customers/bi-monthly 600 storm drains have been stenciled, involving 6 groups of scouts. The City staff held two (2) presentations at Park Hill and North Kansas City School District-High Schools, respectively. The content included topics such as: how water cycle works, why detention is important, what is a watershed, and how to prevent illicit discharge. Several hundred of high school students and their teachers attended these events. Door hangars, carrying the message of how to keep oil and grease out of sewers, were distributed to residents. There were seven classes and nearly 350 food business owners attending the presentations on how to protect the City’s sewer system. The classes were conducted as part of Food Code education training co-sponsored by the City’s Health Department and Water Services Department. The Blue River Summit and Brush Creek Summit were attended by approximately 200 and 60 participants, respectively. These participants are from various interests (governmental officials, environmental groups, business interests, neighborhood representatives, technical experts, nonprofit organizations, and the general public) in each watershed. The discussion focused on basin planning and water quality.



Final 62 12/22/05

Next Steps

The staff will continue to update the web pages on stormwater education as needed. Additionally,

more information regarding the MS4 permit implementation progress, such as illicit discharge

detection, stormwater monitoring results and programmatic progress will be made available

through the website.

Several activities are currently underway:

� Continuing to facilitate the 2005 Missouri River Watershed Festival – a Week of

Water event (Week of Water Festival renamed for clarification);

� Planning demonstrations on “How to Construct Rain Barrels”, and coordinating the

distribution of barrels as requested by the public;

� Designing catch basin labels stating “stormwater only”, and seeking approval of

concrete “Only Rain in the Drain” stamp on new concrete catch basin tops city-wide;

� Developing two demonstration rain gardens that will be designed and constructed on

the City’s property; and

� 10,000 Rain Garden initiative.



Final 63 12/22/05

6. WATERSHED MONITORING PROGRAM

Background

Protecting, restoring, and enhancing stream water quality at levels consistent with the State of

Missouri’s water quality standards are the ultimate goals of the MS4 permit implementation.

Monitoring water quality is a critical component in evaluating achievements associated with this

goal. The City is establishing a watershed monitoring program to address the monitoring

requirements identified in the Permit. This program targets both stormwater discharges and

receiving waters. The general goals are to gauge the quality of stormwater discharges from the

MS4, to assess their impact on receiving waters, and to evaluate the effectiveness of best

management practices used to reduce these impacts. The program comprises three major

elements: (1) representative stormwater runoff monitoring, (2) in-stream ambient monitoring, and

(3) biological monitoring (see Table 13). The long-term objectives of the program are to monitor

the temporal trend of constituent loadings contributed by stormwater runoff from representative

land uses and to assess the impact of MS4 discharges on receiving waters through water quality

and biological monitoring.

The current City boundary encompasses, in part or whole, more than 35 watersheds (Figure. 11).

Approximately two thirds of these watersheds are located north of the Missouri River. The

remaining watersheds are located south of the river, with seven of them partially or completely

within the combined sewer system (CSS) boundary. The monitoring effort discussed here,

focuses on the streams, watersheds, or portions of watersheds that are exclusively served by the

MS4. Additional monitoring in the CSS is being conducted by the City as part of our Overflow

Control Program (OCP) and development of a combined sewer overflow (CSO) Long-Term

Control Plan.

Program Objectives

The objectives of the program for the first permit year were to:

• Characterize stormwater discharge quality from representative land uses;

• Initiate the development of a monitoring plan on receiving water quality to assess the

MS4 impacts;



Final 64 12/22/05

• Initiate the development of a biological sampling plan to assess receiving water

ecosystem conditions.

Table 14 summarizes specific tasks and activities that were established to fulfill the short-

term objectives.

Discussion

1. Develop a representative stormwater Permit Ref. VI.A.1 discharge monitoring plan Status: Completed

The City contracted Limno-Tech Inc. (LTI) to develop a plan to monitor storm water discharges

at the six designated locations (Figure 10) identified in the permit. Each site is associated with a

major land use category. The plan consists of four major parts:

� Monitoring, which includes monitoring objectives, locations, frequency,

coordination, standards, and field measurements;

� Sampling, which includes sample collection, handling, and delivery;

� Documentation, which includes field documentation forms; and

� Heath and Safety, which includes safety precaution information, emergency

procedures, and other relevant procedures

The plan was created to comply with the Permit requirements. Note that a parallel effort to

characterize wet weather discharges from combined sewer overflows (CSOs) within the City is

also incorporated in the plan. The plan includes sampling at each location for three discrete

rainfall events during the permit year. The targeted precipitation ranges in the first three hours are

0.25-0.5 inches, 0.5-1.0 inches, and >1.0 inches, respectively. During each sampling event,

automated samplers were programmed to collect three discrete samples, one from each of the first

three hours of discharge. Each sample was analyzed separately to provide temporal information

about each individual storm event. The plan specifies the field documentation forms and sample

labels to maintain consistency of sampling activities.



Final 65 12/22/05

�

Legend

! SamplingPoints

ms_kclimit_area

ms_watershed_boundary

OCP_CSS_StudyArea

0 5 102.5 Miles

!

!

!

!

!

!

#802

#805

#801

#804

#806

#803

Figure 10. Stormwater sampling locations



Final 66 12/22/05

In addition to the monitoring plan, the City developed a quality assurance project plan (QAPP).

Quality assurance is achieved mainly through (1) using standard procedures for sample

collection, storage, and transport including the use of appropriate chain-of-custody procedures;

(2) controlling laboratory analysis by using EPA or other standard methods including replicates,

matrix spikes, matrix spike duplicates, control samples, and method blanks; and (3) reviewing,

validating, verifying the obtained data.

2. Compile a GIS database for the six sampling stations Permit Ref. NA Status: On-going

A GIS database of the six sampling stations is being built. The database is used to file background

information, maintain analytic data result, map relevant information, and provide a linkage to

other data sets for modeling or other purposes. Currently, the compilation of background

information about these sampling points has been finished. See Table 15 for details. Note that

each drainage basin is served by the MS4. Major land use types monitored are residential,

commercial, and industrial.

3. Monitor stormwater discharges Permit Ref. VI.A.1 Status: On-going

Stormwater discharge sampling was performed by MEC Water Resources Inc., a contractor with

the WSD. The sampling activities were initiated in April 2005 and continued through July 2005

or until three events are sampled at each location (Figure 11). As of April 30, 2005, the end of

this reporting period, one storm event was sampled and it occurred at the location #802 (Figure

10). One storm water sample was collected during the event. The sample was analyzed by the

contract laboratory - Severn Trent Laboratory (STL), a National Environmental Laboratory

Accreditation Program (NELAP) certified lab.

4. Collect and compile storm event data Permit Ref. VI.A.1 Status: On-going The sampled storm event occurred from April 25 to 27, 2005. The precipitation was

approximately 0.25 inches. Monitoring results are forthcoming.



Final 67 12/22/05

Left: Sampler storage unit at a residential site; Right: Programming sampler Figure 11. Field sampling equipment

5. Provide a description of sampling and analytical methods Permit Ref. VI.A.1 Status: On-going Complete sampling and analytical methods are described in the attached sampling plan and

QAPP.

Next Steps

Stormwater runoff monitoring activities and laboratory analysis required for the first Permit year

have been finished during the report preparation time. Currently, the Stormwater Utility Division

and Limno-Tech, Inc. are reviewing and analyzing the data. The results will be presented in the

next annual report.

At the same time, the WSD is currently preparing to conduct monitoring in year two of the

permit. Additionally, the Stormwater Utility Division, with technical support from Limno-Tech,

Inc., is developing the followings:

� An in-stream ambient monitoring plan to assess the impacts of MS4 discharges on

receiving waters (Permit Ref. VI.B.).

� A biological sampling plan to evaluate the quality of stream ecosystems (Permit Ref.

VI.C.)

Both plans will be completed by March, 2006, as required by the permit.



Final 68 12/22/05

Table 13. Watershed monitoring – major program elements and timeframe for the Permit term

Permit

Reference Sept. 2004

Sept. 2005

Mar. 2006

Sept. 2006

Sept. 2007

Sept. 2008

Sept. 2009

VI.A Develop and implement a representative monitoring plan

Update and implement the monitoring plan on an annual base

VI.B Develop an in-stream ambient monitoring action plan

Implement the in-stream ambient monitoring action plan

VI.C Develop a biological monitoring action plan Implement the biological monitoring action plan

Table 14. Watershed monitoring – summary of current work progress

Permit

Reference

Cate-

gories

Task Status Due Date Comment

1. Develop a representative monitoring plan Completed Sept. 2005 Attachment 2

2. Compile a background database for the six sampling stations Completed NA Attachment 2

VI.A.1

3. Monitor storm water runoff at the six designated stations with representative land uses

On-going Sept. 2005

VI.A.2 4. Collect and compile storm event data On-going Sept. 2005

VI.A.3 Representative

Monitoring

5. Provide a description of sample type, collection method, and analytic method. On-going Sept. 2005

VI.B

In-Stream

Ambient

Monitoring 6. Develop a monitoring action plan to assess the impacts of MS4 discharges on

receiving waters. On-going Mar. 2006

VI.C

Biologic

Monitoring

7. Develop a biological sampling action plan, including the following information: a. Rationale for selecting sampling stations; b. Location of sampling stations; c. Location of MS4 major outfalls discharging to waterbodies where sampling

stations are located; d. Nearby land use activities; e. Monitoring frequency.

On-going Mar. 2006

NA: not applicable.



Final 69 12/22/05

Table 15. Background information for the monitoring stations

DRAINAGE AREA Monitoring

Station LOCATION GPS

RECEIVING

STREAM

SAMPLING

POINT ACREAGE LAND USE

1

#801 SE 50th Terrace & Sterling

N39°01’52”/

W94°26’52”

Round Grove Creek

Concrete channel

257 85% Residential, 10% Institutional, 5% Others.

#802 SE Wyandotte & 135th Street

N38°52’45” /

W94°35’55”

Tributary to Blue River

Outfall 23 50% Industrial, 30% Commercial, 10% Residential, 10% Others.

#803 N Everton Ave & NW 104 Street

N39°16’55”/

W94°40’41”

Brush Creek North

Outfall 46 45% Industrial1, 40% Undeveloped, 15% Roads

#804 49th Street & N. Highland

N39°10’58”/

W94°33’35”

Rock Creek In-stream 44 90% Residential, 10% Parks/Recreation

#805 S.Holmes Road & Minor Drive

N38°55’12”/

W94°35’13”

Tributary to Blue River

Concrete pipe

12 60% Institutional, 40% Commercial

#806 Barry Rd. & I-29 N39°14’48”/

W94°39’08”

Line Creek Culvert 60 65% Commercial, 30% Roads, 5% Others.

1. Land use percentages were estimated from the City’s general zoning data, and corrected for individual parcels (only for the drainage area of #803)

using KIVA system- a database for the City’s land information and permitting record.



Final 70 12/22/05

7. OTHER PERMIT REPORTING REQUIREMENTS

7.1 Summary of Implementation Status

Stormwater Management Program (SWMP) components are being implemented and are

proceeding in accordance with the City’s Permit requirements. The status of each program

element has been described in each individual program section of this report. This first report,

covering partial year, addresses activities that occurred by the end of FY 2004/05 (April 30,

2005). This precedes the end of the first permit year (September 2, 2005) by four months. As a

result, a number of activities that occurred between May and September, 2005 are not necessarily

reflected in this report, but will be documented in the next annual report.

The timely implementation of the Stormwater Management Program in this first abridged

reporting period has benefited from a number of pre-existing programs. Throughout the 1990’s

the City independently established and developed programs supporting stormwater pollution

prevention efforts in a variety of ways, and examples include the following efforts:

� Household Hazardous Waste Program;

� Storm Drain Stenciling Program;

� Stormwater Drainage (Watershed) Master Plans;

� Development of a geographic information system to maintain and identify

stormwater drainage systems;

� Stream Asset Inventory projects;

� Leaves and Brush Collection;

� Operating four Community Recycling Centers through a partnership with

Bridging the GAP; and more recently,

� Oil and Grease Program;

� KC Recycles Program;

� KC-One City-wide Comprehensive Stormwater Master Program; and

� GO Bond-funded Catch Basin Replacement Program.

The City will continue its effort to not only ensure its compliance with the MS4 Permit, but also

to improve upon existing programs and implement new stormwater pollution prevention practices



Final 71 12/22/05

to protect our streams and rivers. Protecting our stormwater sewer systems is our strategy, and

restoring and enhancing our water quality is the ultimate goal.

7.2 Proposed Changes

During the past eight months of permit implementation, no significant change of permit

conditions has been identified for modification. The following general issues, however, have been

identified:

(1) Part III.A.1.b of the permit requires that the City implement a maintenance program for the

storm water regional detention basins owned or operated by the City. Part IV.A.1.c requires a

submission of a description of such maintenance activities in Year 1 Annual Report.

As our current investigations show, the City does not own or operate any regional detention

basins, thus no maintenance activities can be reported as required. However, the City does inspect

and maintain public detention basins as needed. The City also conducted standard inspection of

private detention basins to certify stormwater impervious surface fee credits as an incentive for

BMP use. Such information has been compiled and included here in the annual report Part 4.1:

Post-Construction Discharges from Areas of New Development and Significant Re-development.

A maintenance program will be developed to address regional detention basins that are planned

and constructed for new development or redevelopment. Progress in implementing this program

will be reported in the next annual report.

(2) Part III.A.5.a requires updating the inventory of industrial and other high-risk dischargers.

The City did not have such an inventory when the Permit was issued. The City has since

developed such a list as well as a corresponding GIS database, and will update each as

appropriate and necessary.

Since this report is being drafted before the end of the first permit year, and several programs are

still under development, no changes in Permit conditions are currently anticipated. If such a need

arises in the future, the City will send written notification to the Water Pollution Control Program

Permits Section for approval, following the procedures as described in Part III. G. in the Permit.



Final 72 12/22/05

7.3 Program Effectiveness Evaluation Regarding Water Quality Improvement

Program evaluation is an indispensable part of the continual development of the City’s

Stormwater Management Program. An integrated evaluation can gauge the effectiveness of

relevant activities, pinpoint the strengths and weaknesses of the program, monitor the program

progress, identify resource needs, assure compliance with the Permit requirements, and

ultimately, improve the performance efficiency. Nevertheless, the evaluation of the SWMP

effectiveness in improving water quality is a challenge due a number of common reasons

including:

� The ubiquitous and diffuse nature of stormwater runoff pollutants present in an urban

setting;

� The length of time for the effects of BMPs to take place;

� The lack of sufficient water quality baseline data as reference; and

� The complexity of contributing factors impacting water quality.

Despite these challenges, the City has made the first attempt to evaluate the SWMP by reviewing

the available historical records that exist for some programs (Figures 12 through 16). Our

preliminary assessment indicates that the City has, over the years, reduced non-point source

pollutant loadings into the streams or other surface water bodies.

Figure 12 provides data on the Keep Kansas City Beautiful Program, an affiliate of Keep

America Beautiful. This program has continued its success in litter abatement, education and

community awareness efforts. Over the years, there have been an increasing number of volunteers

from neighborhoods, businesses, governments, and community organizations that devote more of

their time to this program.

Figure 13 shows the quantity of materials that the Regional Household Hazardous Waste

Collection Program received in the first two quarters of each year since 1997. The program has

diverted an increasing amount of household hazardous waste away from the landfills and streams,

and has reduced its cost per pound to under $0.60 from an original $3.00.



Final 73 12/22/05

0

3000

6000

9000

2000-2001

2001-2002

2002-2003

2003-2004

2004-2005

Volunteers

0

10000

20000

30000

40000

50000

Volunteer hours

Volunteers Volunteer Hours

0

500

1000

1500

2000

2500

2000-2001

2001-2002

2002-2003

2003-2004

2004-2005

Litter collected (ton)

0

150

300

450

Illegal dumpsites cleaned

Tons GAC Illegal Dumpsites

Left: volunteers and volunteer hours; Right. litter collected and illegal dumpsites cleaned.

Figure 12. 2000 – 2005 Keep Kansas City Beautiful Program record

1st Quarter

0

40,000

80,000

120,000

160,000

200,000

1997 1999 2001 2003 2005

Lb

s

2nd Quarter

0

200,000

400,000

600,000

1997 1999 2001 2003 2005

Figure 13. 1997 – 2005 Regional Household Hazardous Waste Collection Program –

Quarterly comparison

Figure 14 presents a summary result of illegal dumping investigation during 1998 and 2004,

another perspective of the City’s commitment to protecting the environmental quality.



Final 74 12/22/05

0

5

10

15

20

25

30

35

40

45

1998 1999 2000 2001 2002 2003 2004

Prosecution by ECU Conviction

Figure 14. 1998-2004 Illegal dumping prosecution result by Environmental Crime Unit

Street sweeping is a routine method to keep pollutants out of stormwater drainage systems and to

maintain a clean environment. Note that the decline of actual street miles swept for FY02/03 (Fig.

15) was due to a city-wide sweeping for a February ice storm in May and June of that year. The

decline for FY 04/05 was mainly attributed to two factors: a funding shortage, and longer travel

distances due to the expanded growth in the City. However, the improvement of some existing

programs (e.g., Neighborhood Cleanup events, Keep Kansas City Beautiful – Litter Abatement)

and development of new programs (e.g., city-wide curbside recycling – KC Recycles) could help

leverage the effect of street sweeping, as evidenced by the improvement of litter index from 2.10

in 2002, 1.69 in 2003, and 1.47 in 2004.

10000

20000

30000

40000

1999/00 2000/01 2001/02 2002/03 2003/04 2004/05

Actual miles swept

20000

25000

30000

35000

Debri collected (cubic yard)

Swept miles Debris

Figure 15. 1999-2005 Machine Sweeping Program record



Final 75 12/22/05

Figure 16 shows the record of city-wide catch basin replacement program during 1997-2005.

Note that the costs for 2004 and 2005 are both authorized bidding amounts. The number of inlets

replaced in 2005 is the target number. The substantial increase of inlets number from 2004 to

2005 is attributed to the General Obligation(GO) Bond-Funded Catch Basin Replacement

Program. Replacement of deteriorated stormwater structural controls is a priority for the WSD.

$-

$2,000,000

$4,000,000

$6,000,000

$8,000,000

$10,000,000

1997 1998 1999 2001 2002 2004 2005

Actual expen

se

0

500

1000

1500

2000

2500

Number of inlets

Actual Expense Number of inlets replaced

Figure 16. 1997-2005 city-wide catch basin replacement program record

7.4 Data Summary

The storm event monitoring has been initiated. The results will be received during the fall of

2005, and will be compiled in the next annual report. The development of receiving stream

monitoring and biological sampling plans is underway.

7.5 Annual Expenditures

Table 16 provides a breakdown of the cost for the programs/activities that can be associated with

stormwater management. There are several items of special note:

� A substantial portion of traceable programmatic costs are attributed to many longstanding

programs



Final 76 12/22/05

Examples of pre-existing programs include the Machine (Street) Sweeping program and Leaves

and Brush Collection. The initial purposes for establishing these programs might not be directly

related to addressing the MS4 Permit compliance; however, they do play a role in preventing

stormwater pollution and improving stormwater quality. Their existence and growth can have a

positive impact on the future of stormwater management in the City. Hence, these programs are

listed here to record the actual trackable expense for the City in helping keep pollutants out off

stormwater runoff.

� Non-tracked cost: stormwater-related service provided but blended with other non-

stormwater-related service

An example of a “blended” program is the Oil & Grease Program. The program was created to

perform inspections of food businesses and facilities to prevent oil & grease from entering the

City’s sanitary or storm sewer system. It is difficult to separate the costs applicable to either

sanitary or stormwater systems. The program is not considered in the budget estimates, but its

impact on stormwater has been recognized in other parts of the report.

� Parallel efforts to address one issue

The activities associated with stormwater pollution prevention are spread throughout various

programs/divisions/departments in the City. An example is the City’s response to illegal

dumping. The Environmental Crime Unit (ECU, in Department of Environmental Management

prior to the end of FY 04/05, now in Department of Neighborhood & Community Services)

investigates and prosecutes such incidents. The Solid Waste Division (SWD, in Department of

Environmental Management prior to the end of FY 04/05, now in Department of Public Works)

performs cleanup when necessary. The Street & Traffic division of Public Works Department

also performs some illegal dumping cleanup as needed. Additionally, the Neighborhood Cleanup

Assistance Program (in Department of Environmental Management prior to the end of FY04/05,

now in Public Works) organizes neighborhood home associations and volunteers to address

illegal dumping during neighborhood cleanup events. In situations such as this, only the principal

effort by ECU and SWD is included in the table. Nevertheless, the importance of the other

parallel, complementary and very successful efforts is noted.



Final 77 12/22/05

Table 16. Overall budget for programs/activities supporting stormwater management effort

in FY 04/05 Program/Service Funding Source Est. Expenses

FY 04/05

Est. Budget

FY 05/06

Direct cost – 1 (City-wide manpower investment for programmatic development)

Permit administration – Stormwater Utility Division: staff including management and administration level 1 & MS4 teams event

Stormwater Fund 165,100 170,100

Programmatic development2 Various Funds 49,200 28,000

Sub-total 214,300 198,100

Direct cost – 2 (Newly-created activities to ensure compliance with the Permit)

Ambient monitoring (including biological monitoring)

Stormwater Fund 03 03

Flood control projects – BMPs incorporation PIAC Fund4 0 40,000

High-risk-runoff facility inspection Stormwater Fund 0 3,000 Illicit discharge screening Stormwater Fund 0 5,000 KC-One city-wide comprehensive stormwater master plan ( including stream asset inventory – Phase II)

Stormwater Fund 314,300 2,040,000

Landfill monitoring General Fund 3,500 3,500

Stormwater monitoring 5 Stormwater Fund 55,000 176,000

MS4 compliance consulting support General Fund 06 40,000

Sub-total 372,800 2,299,500

Indirect cost (Pre-existing activities that help with stormwater pollution prevention effort)

Leave & brush drop-off site operation and maintenance

General Fund 433,200 07

Leave & brush collection (curbside) General Fund 254,200 07

Bulky item collection General Fund 1,696,700 1,664,348

GO-Bond Catch Basin Replacement program General Obligation Fund

1,275,000 10,693,0158

Catch basin cleaning & repair (including other inlets, outfalls, ditches, channels, etc.) by Stormwater Maintenance Division

Stormwater Fund 2,961,000 3,331,993

Deicing, snow/ice program Motor Fuel Tax 2,298,700 1,250,000

Household hazardous waste program Sewer Fund 775,400 925,700

Illegal dumping cleanup & enforcement General Fund 619,900 679,700

KC Recycles (Recycle First) program General Fund 1,833,900 3,398,800

Keep Kansas City Beautiful General Fund 50,000 50,000

Levee maintenance Stormwater Fund 14,500 16,800

Machine sweeping program Motor Fuel Tax 967,100 514,900

Right-of-way (floodplain) acquisition PIAC Fund 700,000 700,000

Sub-total 13,879,500 23,225,900

TOTAL 14,466,600 25,723,500 1 Fringe benefit is included. 2 The amount is a result of the accumulated staff hours × average hourly salary × 1.35 (fringe benefit). Here, the accumulated staff hours refers to the total hours that MS4 teams consisting of city-wide staff, other than permit administration staff, had spent on developing new programs and enhancing existing services per the permit requirement. The decrease of the estimated budget for the current fiscal year is attributed to the fact that with the good foundational development by each team and help from consulting services, more specific work is being conducted by individuals in the Stormwater Utility division. 3 The cost has been included in the Permit administration.



Final 78 12/22/05

4 PIAC Fund: the Sales Tax through Public Improvements Advisory Committee. 5 The major portion of this cost for FY04/05 includes the preparation work (e.g., making plans for sampling/quality control/assurance, instrument renting, field/laboratory coordination). The majority of monitoring events occurred during the summer of 2005. Their cost and associated laboratory service fee are included in estimated budge for FY05/06. 6 The FY 04/05 amount for MS4 compliance consulting support is included in the expense of KC-One program. 7 Budgeted to be privatized for FY 2005-06 8 See p.g. 29 for details on the budget increase.

� The CSO/MS4 geographic boundary not recognized in budget analysis

Approximately one sixth of the City in area size is served by combined sewer systems (CSS).

There are separate regulations and policies to address CSS. However, most of the existing city-

wide services are not affected by this boundary. In addition, the varied demographic and socio-

economic conditions within and between CSS and MS4 areas make it impractical to use a simple

fraction of each program budget based on area size. The City’s services are provided to residents,

regardless of the system area in which they live.

� Actual expense for FY 04/05 reflecting the cost of programmatic development

During this reporting period, the primary city-wide effort incurred from MS4 permit focused on

developing programs that had not existed and that are required by the Permit. Examples include

the High-risk Runoff Facility Inspection program, Representative Monitoring program, and the

Dry-weather Screening program. Additional effort was spent on improving existing services by

direct involvement of a number of city staff based on their current job functions. Hence, a

significant portion came from city-wide manpower investment. As these new programs become

fully implemented, the actual cost of compliance will be refined.

7.6 Activity Summaries – Inspection, Enforcement, and Public Education

Table 17 summarizes the enforcement, inspection, and public education activities that are relevant

to stormwater issues.



Final 79 12/22/05

Table 17. Activity summary – inspection, enforcement, and public education

ENFORCEMENT ACTION

Illegal dumping investigation by Environmental Crime Unit

Investigation Prosecution Result

Sites Individuals Not guilty Dismissed Guilty Warrant Reissue Pending

55 58 4 9 29 12 1 3

INSPECTION

Detention basin

Public detention basin: 5 Private detention basin: 14

Catch basin/Inlet

Stormwater Maintenance Division: 15,937 Stormwater Utility Division: 1,040

Levee

Missouri River: 22.2 miles Blue River: 5.3 miles

Impervious (runoff) surface: 300 sites

Inactive landfill: 4

Industrial facility: 4

TV sanitary sewer line: 73 miles

Active construction site (erosion & sediment control)

Private development City projects (various area sizes) ≤ 1 acre > 1 acre

40 (including repeated inspections) 420 >134*

MUTI-MEDIA PUBLLIC EDUCATION

Regional efforts

Co-sponsor the

Week of Water

Festival

Co-develop education brochures

Lead sponsoring Keep Kansas City Beautiful

Presentations on curbside recycling

Presentations on litter, recycling in general, and other environmental issues

1200 attendees 4

200 17 380 attendees

Maintain and update the website “Stormwater Education and Involvement”

Distribute education material

Bill inserts: >185,000 customers/bi-monthly Door hangars Material posting

Bring stormwater education into classroom

2 presentations attended by several hundred high school students and teachers

Stencil storm drains: approximately 600

*The City’s recording system (KIVAnet) keeps track of the basic information for each land disturbance permit (land size > 1acre) for new private development. During a permit’s life time, site inspection of erosion control is performed regularly by the Development Inspection group. Due to its high frequency, daily inspections are not logged into the recording system. Thus, the exact total number of inspections is unavailable. However, according to the KIVA system, there were 134 permits active during the past fiscal year.



Final 80 12/22/05

7.7 Water Quality Degradation / Improvements

Given that Stormwater Management Program implementation is in its early stages and that

minimal water quality monitoring has been performed thus far, the City has not yet identified

water quality degradations or improvements. The City, however, is developing a water quality

monitoring action plan for receiving streams. With more baseline data available, the City will be

able to assess water quality issues and eventually to evaluate the effectiveness of the BMPs. At

this point, the City can only make assumptions on the improvements to the City’s water quality

based on the amount of potential waste removed from the system including:

� Over 1 million pounds of household hazardous waste collected, recycled, and properly

disposed of in 2004;

� Approximately 14 thousand tons of material recovered by recycling activities during

2004/05, and;

� Over four thousand tons of leaves and brush collected during 2004/05.

As a result of these efforts, these materials are not getting into storm drain systems and

contaminating our local waterways.



Final 81 12/22/05

8. FUTURE IMPLEMENTATION

This report provides a review of the first eight-month implementation of the Kansas City,

Missouri’s MS4 permit. Referring other cities’ experiences and lessons in implementing similar

NPDES permits, the City is aware of the challenges that it may face. The following listing

presents a vision for the near future regarding the permit activities:

� Ensure policy support: The City will continue to make sound stormwater-related policies

and to put them in place (e.g., authorizing the update APWA 5600 as city-wide drainage

system design standards).

� Actualize strategic stormwater management plan: While the City continues to develop the

comprehensive KC-One Stormwater Management Plan, many recommendations,

regarding Best Management Practices and water quality improvement policies, will be

incorporated into practice as appropriate.

� Improve the existing services: Key efforts shall focus on:

a. Securing funding;

b. Improving the documentation/recording methods and tracking systems;

c. Seeking opportunities to incorporate water quality consideration wherever

necessary and whenever possible; and

d. Promoting city staff’s awareness on stormwater pollution, especially those whose

work can directly impact stormwater quality.

� Implement the newly-developed programs: The City has begun implementing the

programs that have been developed in compliance with the Permit, and will closely

monitor and evaluate the progress.

In summary, the City’s goal is not only to comply with the state and federal regulations but also

to prevent and ameliorate stormwater pollution.



Final 82 12/22/05

ATTACHMENTS

A-1 Inventory of High-Risk Runoff Dischargers

A-2 Stormwater Runoff Monitoring: Sampling Plan, and Quality Assurance

Project Plan (QAPP)

Last Update: Dec. 2005, Industrial and High-Risk Dischargers Inventory for MS4

MAP ID Rank Organization Address Watershed

Storm

Sewer

System

Contact Name

911 Walnut Street L.L.C. 909 Walnut Street NEID CS

AK Steel Corporation 7000 Roberts Blue River CS Carl Batliner

Allied Aviation Service Company 217 Bern Street Todd Creek MS4 Genevieve Almskog

Amerex - Waste Express Incorporated 6300 Stadium Drive Blue River CS Rob Boyd

American Airline M&E Base 9200 N.W. 112TH Street Todd Creek MS4 Fred Augustine

Aptuit Kansas City L.L.C. 10245 Hickman Mills Drive Hickman Mills Creek MS4 Pam Barton

Aventis Pharmaceuticals 10236 Marion Park Drive Hickman Mills Creek MS4 David Eggers

Ball Metal Beverage Container Corporation 1800 Reynolds Avenue NEID CS Robert Turner

Bayer Crop Science 8400 Hawthorne Road NEID CS Patrick Ragan

Beazer East Incorporated 6740 Stadium Drive Blue River CS

BNSF Gibbon Lumber Site 1301 W. 13TH Street CID CS

Boulevard Brewing Company 2501 Southwest Boulevard Turkey Creek CS Michael Utz

Brady Enterprises D.B.A. A-Luster 1019 W. 24th Street Turkey Creek CS David Collins

Brenntag Mid-South Incorporated 5200 Stillwell Avenue NEID CS David Leigh

Brock Grain & Feed 7400 E. 13TH Street Blue River CS Ken Mason

Cargill Incorporated - Soybean Processing Plant 2306 Rochester NEID CS James Alfieri

Cargill Incorporated Choteau Elevator 4801 N.E. Birmingham Road Buckeye Creek MS4 Gerald W. Wedel

Carter Waters Corporation 2440 W. Pennway Street Turkey Creek CS David Dudley

Charles Paint Research Incorporated 2401 E. 85th Street Blue River CS Dallas Cochran

Chemcentral - Kansas City 910 N. Prospect NEID CS Craig W. Nienhuesrt

Clay & Bailey 6401 E 40TH Street Blue River CS

Compass Big Blue L.L.C. 8116 Wilson Road Blue River MS4 Don Sanders

Cook Brothers Insulation Incorporated 1405 Saint Louis Avenue Birmingham Bottoms MS4 Roy L. Cook

DuPont Refinish Service Center 6015 Manchester Trafficway Blue River CS

Environmental Specialists, Incorporated 3001 E. 83rd Street Blue River MS4 Alan Wolfe

Fordyce Concrete Company Incorporated - Randolph Facility 3700 N. Skiles Road Randolph Creek MS4 Doug Berger

Fresh Express Foods-formerly Redi Cut Foods Incorporated 3951 N.E. Kimball Drive Birmingham Bottom MS4 Randall Kirk

Gateway Packaging Company 5910 Winner Road Blue River MS4 Fern Ricketts

General Mills Operations Incorporated 2917 Guinotte Avenue NEID CS Mike Simms

Hallmark Cards, Incorporated 2501 McGee Turkey Creek CS Lance Erickson

Harley-Davidson Motor Group Company 11401 N. Congress Avenue Todd Creek MS4 Theresa Chevas

Havens Steel Company 7219 E. 17TH Street Blue River CS Gregory J. Ward

Hawthorn Generating Facility 8700 Hawthorn Road NEID CS John E. Horn

Heritage Environmental Services 8525 N.E. 38TH Street Randolph Creek MS4 Tanya Cotton

Hiles Plating Company 2028 Broadway Turkey Creek CS Stephen Gaunt

HP Management Incorporated 11103 N. Nashua Drive First Creek MS4

Jackson Plating & Polishing, Incorporated 2641 Jackson Blue River CS Michael Sambursky

Kansas City Screw Products Incorporated 2908 Truman Road Blue River CS

KC Southern Railway - Knoche Yard 3651 E. Front Street NEID CS Chester Culley

Page 1 of 4


KCMO American Royal Arena Complex 1800 Genessee CID CS Dean Barrett

KCMO Animal Control Kennel 4400 Raytown Road Round Grove Creek MS4 Kent Offill

KCMO Birmingham Wastewater Treatment Plant 10801 N.E. 28th Street Birmingham Bottoms MS4 Denise Burkett

KCMO Blue River Golf Academy 7501 Blue River Road Blue River MS4 David Buie

KCMO Blue River Secondary Wastewater Treatment Plant 7600 Front Street NEID CS Denise Burkett

KCMO Blue River Wastewater Treatment Plant 7300 Hawthorne Road NEID CS Denise Burkett

KCMO Buckeye Maintenance Facility 5001 Birmingham Randolph Creek MS4 Denise Burkett

KCMO Camp Lake of the Woods Oakwood Drive in Swope Park Blue River MS4 David Buie

KCMO City Tow Lot 3800 Raytown Road Blue River MS4 Kent Offill

KCMO City Zoo 6900 Zoo Drive Blue River CS Gary Norman

KCMO Downtown Airport 250 Richards Road Missouri River Basin MS4 Michael Roper

KCMO Fire Training Academy 5130 Deramus NEID CS Bob Lawler

KCMO Fleet Operations 5215 E. 27th Street Blue River CS Richard Garne

KCMO Helicopter Unit 4601 Eastern Round Grove Creek MS4 Richard Garne

KCMO Hodge Golf Course 7000 N.E. Barry Road East Fork Creek MS4 David Buie

KCMO KCI Airport 125 Paris Street Todd Creek MS4 Bob Jones

KCMO Kemper Arena 1800 Genessee CID CS Dean Barrett

KCMO Leaf & Brush Drop off site I-470 & Raytown Road Little Blue River MS4 Michael Shaw

KCMO Maintenance facility 1800 Prospect Turkey Creek CS Denise Burkett

KCMO Minor Golf Course 111th & Holmes Blue River MS4 David Buie

KCMO Municipal Service Center 5300 Municipal Avenue NEID CS Michelle Tevis

KCMO Nursery 5400 E. Gregory Avenue Blue River MS4 David Buie

KCMO Pacaar Building & Lot 1301 Chouteau Trafficway NEID CS David Buie

KCMO Parks District 2 3915 Gillham Road Brush Creek CS David Buie

KCMO Parks District 3 6901 Elmwood Avenue Blue River CS David Buie

KCMO Pistol Range 6900 Coal Mine Road Round Grove Creek MS4 Richard Garne

KCMO Public Works District 1 2400 Russel Road Rock Creek MS4 Michelle Tevis

KCMO Public Works District 3 4725 Coal Mine Road Blue River MS4 Michelle Tevis

KCMO Regional HHW Facility 4707 Deramus Avenue NEID CS Bill Lewry

KCMO Richards Gebauer Airport 15405 Maxwell Avenue Blue River MS4 Bob Jones

KCMO Ruskin Maintenance 11231 Bennington Hickman Hills Creek MS4 Denise Burkett

KCMO Solid Waste Headquarters 1815 N. Chouteau NEID CS Michael Shaw

KCMO Swope Memorial Golf Course 6900 Swope Memorial Drive Blue River MS4 David Buie

KCMO Traffic Operations 5310 Municipal Avenue. NEID CS Michelle Tevis

KCMO Water Treatment Plant 1 NW Briarcliff Line Creek MS4 Denise Burkett

Page 2 of 4


KCMO Westside Wastewater Treatment Plant 1849 Woodswether Road CID CS Denise Burkett

KCS Elevator 1031 N. Topping NEID CS John Geabhart

KCT Elevator 5801 Birmingham Road Searcy Creek MS4 Ramon Harris

Koch Materials Company 4915 Chelsea Street Brush Creek CS Ron Shiver

Lafarge North American Incorporated 3801 N. Arlington Birmingham Bottom MS4 Mike Baker

Lafarge North American Incorporated 3101 E. 85TH Street Blue River CS Terry Brakensiek

Lubar Chemical Company 1700 Campbell Blue River CS

Mallin Brothers Company, Incorporation 3211 Gardner Avenue NEID CS Jeffrey K. Mallin

Martin Foundry Company 1510 Crystal Avenue Blue River CS George Stone

Michelin Aircraft Tire Corporation 8121 N. W. 97TH Terrace North Brush Creek MS4 Jeff Halterman

Mid America Car Incorporated 1523 N. Monroe NEID CS

Midway Ford Truck Center Incorporated 7601 N.E. 38TH Street Randolph Creek CS

Midwest Hanger Company 4312 Clary Boulevard Blue River CS David Stonestreet

Midwest Research Institute 425 VOLKER BLVD Brush Creek CS James McHugh

Mid-West Terminal Warehouse Company 1851 Woodswether Road CID CS David Griffin

Miller Material Company 2405 EAST 85TH Street Blue River CS Tony Wessel

Missouri MPP Corporation 2800 EAST TRUMAN ROAD Blue River CS Charlie Hayes

Missouri Plating Company 7001 EAST 13TH Street Blue River CS Craig Wilson

Monier Life Tile L.L.C. 12600 E. 98 Street Little Blue River MS4 Sandra Glenn

New Surface L.L.C. 7400 E. 12TH Street Blue River CS Ron Knop

North American Galvanizing Company 7700 E. 12TH Street Blue River CS Alvin Love

Package Service Company, L.L.C. 1800 NW Vivion Road Line Creek MS4 Randy Brubeck

Paulo Products Company 4827 CHELSEA Avenue Brush Creek CS Steven Bizub

Penny's Concrete, Incorporated - Parvin Road Plant 8601 NE 38th Street Randolph Creek MS4 Kelly Rauckman

Performance Roof Systems, Incorporated 4821 Chelsea Avenue Brush Creek CS Monty Greenstreet

Permacel Kansas City Incorporated 3900 Empire Road NEID CS Michael Stoppa

Permacel Kansas City Incorporated 8485 Prospect Avenue Blue River CS Michael Stoppa

Quality Finishing Industries Incorporated 7615 E. 17TH Street Blue River CS

Railway Express Agency 300 W. Pershing Road Turkey Creek CS

Research Medical Center 2316 E. Meyer Boulevard Town Fork Creek CS Dan Burkholder

Roberts Dairy Company 3805 S. Emanuel Cleaver Boulevard Brush Creek CS Dayle Reynolds

Rotadyne Roll Group 2035 Washington Street Turkey Creek CS Michael R. Elliott

Solvent Recovery Corporation 716 Mulberry Street CID CS Randal James

Southeast Sanitary Landfill L.L.C. 8301 Indiana Avenue Blue River MS4 Neil Krahn

Speaco Foods, Incorporated 2400 Nicholson Avenue NEID CS Mike Cole

Stone Container Corporation 3244 Gardner Avenue NEID CS Mike McCready

Summit Machine Products, Incorporated 7101 E. 13TH Street Blue River CS Dermot Kerin

Superior Metal Treating & Equipment 2540 Indiana Avenue Blue River CS Larry McCue

Tenneco Automotive 1846 N. Topping Avenue NEID CS Georgie Mihalko

Trigen-KC Grand Avenue Station 115 Grand Avenue NEID CS Jeff Dykes

TruGreen 1740 Reynolds Avenue NEID CS Rich Blattner

U.S. Dept. of Energy-Kansas City Plant 2000 E. 95TH Street Indian Creek MS4 Phil Keary

Page 3 of 4


Union Pacific Railroad 6400 Martin NEID CS Christi Hornic

Univar USA Incorporated - Kansas City 2000 Guinotte Avenue NEID CS Jeff Vernold

University of Missouri, Kansas City 5100 Rockhill Road Brush Creek CS

US Plating & Surface Finishing 1341 Montgall Avenue Blue River CS Tim Hoverder

VA Medical Center 4801 Linwood Boulevard Blue River CS Joy Des Rosier

Vance Brothers Incorporated 5201 Brighton Blue River CS Bryan Midgett

Vopak USA Incorporated - Kansas City 2000 Guinotte Avenue NEID CS Dean Sares

W.R. Meadows of Kansas City 1120 E. 13th Street Turkey Creek CS David Carey

Walker Towel & Uniform 2601 Truman Road Blue River CS Hal Shapiro

Weld Wheel Industries Incorporated 1245 Crystal Blue River CS Hos Evans

Western American Incorporated 1221 W. 12TH Street CID CS

Yellow Transportation (KCM) 3500 Booth Street Blue River CS Kevin Anderson

Zea Corporation 3101 Gardner Avenue NEID CS

Page 4 of 4

Kansas City, Missouri Water Services Department

Overflow Control Program

CSO/Stormwater Sampling Plan Revision 1

June 9, 2005

City Contra

ct 770 – City Project 8100148

CSO/Stormwater Sampling Plan Kansas City, Missouri Water Services Department

Table of Contents

1 MONITORING OBJECTIVE .........................................................................................................1-1

2 QUALITY ASSURANCE PROJECT PLAN..................................................................................2-1

3 HEALTH AND SAFETY PLAN......................................................................................................3-1

4 MONITORING TEAM ....................................................................................................................4-1

5 MONITORING LOCATION AND FREQUENCY.......................................................................5-1

5.1 Monitoring Locations....................................................................................................................5-1 5.2 Monitoring Frequency ..................................................................................................................5-4

6 COORDINATION AND INITIATION OF AN EVENT...............................................................6-1

7 DOCUMENTATION ........................................................................................................................7-1

8 FIELD MEASUREMENTS..............................................................................................................8-1

9 SAMPLE COLLECTION, HANDLING AND DELIVERY.........................................................9-1

9.1 Equipment Installation ..................................................................................................................9-1 9.2 Equipment Configuration and Calibration....................................................................................9-1 9.3 Sample Collection.........................................................................................................................9-1 9.4 Sample Labeling ...........................................................................................................................9-3 9.5 Quality Assurance/Quality Control Samples ................................................................................9-3 9.6 Sample Chain of Custody .............................................................................................................9-4 9.7 Handling and Delivery..................................................................................................................9-4 9.8 Field Records and Documentation................................................................................................9-4

CSO-SW_Sampling_Plan_060905_Rev1.doc REV1 FINAL 6/09/2005 TOC-1


LIST OF TABLES

Table 1-1 Summary of CSO and Stormwater Sampling........................................................................1-2

Table 4-1 Contractor Team Member Responsibilities ..........................................................................4-1

Table 5-1 Monitoring Sites ...................................................................................................................5-2

Table 8-1 Field Measurements..............................................................................................................8-1

Table 8-2 Summary of Observations ....................................................................................................8-2

Table 9-1 Parameter List, Sample Containers, Volumes, and Preservatives ........................................9-2

LIST OF FIGURES

Figure 5-1 CSO/Stormwater Monitoring Locations ..............................................................................5-3

APPENDICES

Appendix A – Field Documentation Form

Appendix B – Standard Operating Procedures

Appendix C – Chain of Custody Document

CSO-SW_Sampling_Plan_060905_Rev1.doc REV1 FINAL 6/09/2005 TOC-2


1 MONITORING OBJECTIVE

The Kansas City, Missouri (KCMO) Water Services Department (WSD) is committed to protecting public health and the environment, meeting water quality regulations and doing so at an appropriate cost. To accomplish this mission, an Overflow Control Program (OCP) has been established within the WSD. The combined sewer system of KCMO can discharge a mixture of stormwater and sanitary sewage to local receiving waters during and following rain events. Characterizing wet weather discharges from combined sewer overflows (CSOs) and separate storm sewer areas is an integral component of the OCP. Therefore, water quality samples from CSOs and separate stormwater discharges will be collected and analyzed as a part of the OCP effort. The sampling of separate stormwater discharges will be conducted to meet the requirements of the KCMO Municipal Separate Storm Sewer System (MS4) permit. The CSO/stormwater sampling described in this Sampling Plan will be used in conjunction with flow metering data and sewer system mathematical models to develop pollutant loads for both monitored and non-monitored CSO and stormwater discharge locations and storms. Therefore, the sampling will cover a variety of land use areas and storm sizes to adequately represent the entire system.

Monitoring will be performed by MEC Water Resources, a WSD Contractor, from April through July, 2005. If sufficient rainfall does not occur during this period, WSD may extend sampling through October, 2005. Samples for laboratory analysis and field measurements will be collected to characterize CSO and stormwater quality. Table 1-1 summarizes the planned sampling effort.

CSO-SW_Sampling_Plan_060905_Rev1.doc REV1 FINAL 6/09/2005 1-1


Table 1-1 Summary of CSO and Stormwater Sampling

Characteristic Number for CSOs

Number for Stormwater Notes

No. Locations 9 6 No. Events 4 3 The following storm sizes will

be targeted (rainfall depth in first 3 hours):

• 1 event with 0.25 to 0.5 inch

• 1 event with 0.5 to 1.0 inch

• 1 event with >1.0 inch A storm event is defined as having at least 0.25 inch of rain with at least 72 hours of dry weather preceding it.

Water Quality Samples

4 discrete samples at each location for each event. Samples collected from the following intervals after initiation of overflow: • 30 to 60 minutes • 90 to 120 minutes • 150 to 180 minutes • 210 to 240 minutes

3 discrete samples at each location for each event. Samples collected from the following intervals after initiation of overflow: • 30 to 60 minutes • 90 to 120 minutes • 150 to 180 minutes

Parameters for analysis in CSOs and stormwater include:

• solids • turbidity • bacteria • oxygen demand • nutrients • metals • hardness

Parameters for analysis in stormwater only include:

• total phenolics, • oil and grease • pesticides • organic base neutral

acids. Field Measurements

Field measurements will be collected at least once during one rain event at each location.

Field measurements will be collected on each discrete sample at each location.

Parameters include: • dissolved oxygen • temperature • pH • conductivity.



2 QUALITY ASSURANCE PROJECT PLAN

A Quality Assurance Project Plan (QAPP) has been developed for water quality monitoring activities being conducted by WSD (OCP Water Quality Monitoring Quality Assurance Project Plan, April 14, 2005). The requirements of the QAPP are applicable to the activities of all participants involved with the implementation of the CSO/Stormwater Sampling Plan. The QAPP includes information on organization, responsibilities, procedures, quality control checks, data management and reporting. The QAPP provides guidance, specifications, and standardized procedures to assure that:

• proper preventive maintenance, equipment calibration, and approved analytical protocols will be implemented so that all field measurements and analytical results will be valid;

• monitoring is conducted using sample tracking systems and Chain of Custody procedures that properly identify samples being collected and insure the control of those samples from field collection through analysis and data reduction;

• records are produced and retained to document the quality of samples collected and analyzed and the validity of applied procedures;

• generated data is validated; and

• calculations, evaluations, and decisions completed or deduced based on the results of the monitoring are accurate, appropriate, and consistent with the objectives of the plan.

Individuals responsible for conducting sampling and analysis as specified in this Sampling Plan must review, become familiar with, and conduct activities in accordance with the requirements of the QAPP.



3 HEALTH AND SAFETY PLAN

A Health and Safety Plan (HASP) has been developed by the Contractor for implementation of this Sampling Plan. The HASP includes safety precaution information and emergency procedures and specifies procedures necessary to comply with all applicable Federal (e.g. OSHA), State, and local regulations, including manhole work and confined space entry.

Individuals responsible for conducting sampling and analysis as specified in this Sampling Plan must review, become familiar with, and conduct activities in accordance with the requirements of the HASP. In addition, all individuals conducting sampling and monitoring activities as specified in this plan must have applicable training certifications as outlined in the HASP.



4 MONITORING TEAM

The monitoring team consists of a project manager, field manager, QA/QC manager, and sampling crews. Responsibilities of each position are listed in Table 4-1.

Table 4-1

Contractor Team Member Responsibilities

Role Contractor Personnel Responsibilities

Contractor Project Manager

Tom Wallace • Implementation of the Sampling Plan

• Resource allocation

Field Managers Cassidy Luebbering and

Nick Muenks

• Staff Training • Coordinate with OCP to initiate sampling

events • Co-ordinate with laboratory and sample

submission • Mobilize field crews • Ongoing management of field staff and

equipment • Submission of field logs

Contractor QA/QC Manager

Rob Kravitz • Collection of field logs, lab results and other program documentation

• Circulation of reports results

Program Support Staff from MEC Water Resources,

Wade & Associates, DuBois Consultants,

and Perfect Personnel

• Field activities



5

5.1

MONITORING LOCATION AND FREQUENCY

This section describes the planned locations and frequency of monitoring for the CSO/Stormwater sampling program.

Monitoring Locations The CSO/stormwater sampling will be conducted at 9 CSO sites and 6 separate stormwater discharge sites. Monitoring locations are described in Table 5-1 and presented in Figure 5-1. These locations represent the range of land uses in both the combined sewer and separate storm sewer areas.



Table 5-1

Monitoring Sites

Combined Sewer Area Sampling Locations

Site ID# At or Near

CSO # Site Location Monitoring Location Description

WQCS-001 NA Blue River WWTP Gate 3 diversion to Blue River upstream of plant headworks

WQCS-002 7 Gardner Avenue

Diversion 24” overflow north of primary plant to Blue Banks structure

then Blue River

WQCS-003 I Turkey Creek Pump

Station 18' x 17' double box culvert overflow to Kansas River

WQCS-004 137 12th & Van Brunt 12’ x 17’ arch sewer overflow to Gooseneck Creek sewer WQCS-005 150 31st & Van Brunt 6’ x 6’ triple box overflow to Blue River WQCS-006 185 45th and Euclid 12” overflow feeds into 92” discharge to Brush Creek

WQCS-007 18 49th Terrace and Westwood Rd

72” overflow to Brush Creek

WQCS-008 110 69th & Cleveland 5' x 7' double box overflow to Blue River tributary WQCS-009 68 83rd Terrace & McGee 72” overflow outlet to Blue River tributary

Separate Stormwater Area Sampling Locations

Site ID# Location Drainage Area (Acres) Land Use

WQSS-801 SE 50th Terrace

& Sterling 257 Residential

WQSS-802 SE Wyandotte &

135th St 23 Industrial

WQSS-803 NW 104th Street &

N Everton Ave 46 Industrial

WQSS-804 49th Street & N Highland

44 Residential

WQSS-805 S Holmes & Minor Drive

12 Commercial

WQSS-806 Barry Road & Interstate-29

60 Commercial



Figure 5-1 CSO/Stormwater Monitoring Locations



5.2 Monitoring Frequency CSOs and stormwater will be sampled during a minimum of 4 and 3 discrete rainfall events, respectively. A discrete rainfall event is defined as having a total rainfall of at least 0.25 inches and at least a 72-hour interval since the last rainfall event. Monitored events will be distributed over the April through July 2005 period. Best efforts will be made to sample one storm event between 0.25 and 0.5 inches in the first three hours; one storm event between 0.5 and 1.0 inches in the first three hours; and one storm event greater than 1.0 inch in the first three hours. A fourth monitoring event in the CSOs can characterize any of these rainfall amounts. Coordination between the sampling contractor and the OCP Office will take place on an event-by-event and month-by-month basis to re-examine the definition of a discreet rainfall event qualifying for sampling, considering the type and number of events sampled to date.

Multiple samples will be collected for each rain event at each location and will be submitted by the Contractor to the Laboratory. At each of the 9 locations in the combined sewer area, 4 discrete samples will be collected. The discrete samples will be collected from the following intervals: between 30 to 60 minutes from the initiation of overflow; 90 to 120 minutes; 150 to 180 minutes; and 210 to 240 minutes. The Contractor will monitor the initiation of overflow and sample accordingly, as outlined in Section 6.0 Coordination and Initiation of an Event.

At the 6 locations in the separate storm sewer area, 3 discrete samples will be collected from the following intervals: between 30 to 60 minutes from the initiation of overflow; 90 to 120 minutes; and 150 to 180 minutes.

All locations may be sampled for the same rain events, or sampling can be rotated through the different locations for separate rain events. Ultimately, 9 locations and 4 events must be sampled in the combined sewer area and 6 locations and 3 events must be sampled in separate storm sewer area between April 1 and July 31, 2005. If sufficient rainfall amounts or patterns do not occur to allow sampling of the specified number of storms between April 1, 2005 and July 31, 2005, WSD may extend sampling on a monthly basis through October 2005. Sufficient rainfall is defined as no less than 11 events meeting the definition of a discrete rainfall event. As stated previously, coordination between the sampling contractor and the OCP Office will take place on an event-by-event and month-by-month basis to re-examine the definition of a discrete rainfall event qualifying for sampling, considering the type and number of events sampled to date.

Additional quality assurance/quality control samples, including field duplicates (approximately 1 in 10 samples) and field blanks (approximately 1 in 20 samples) will be collected and delivered to the Laboratory



6 COORDINATION AND INITIATION OF AN EVENT

The OCP Office, the Contractor, and the Laboratory will identify a contact person and phone number available 24 hours a day and seven days a week during the performance of this work.

The Contractor will monitor weather conditions, and the Contractor Project Manager will contact the OCP Office for each sampling event to assess whether to proceed with sampling, in the case of manual retrieval, or to submit the samples collected by an automated sampler to the Laboratory. Weather forecasts, such as those by Accuweather (www.accuweather.com), National Oceanic and Atmospheric Administration (NOAA), and others, will be consulted when determining whether to initiate sampling.

It is possible that more samples will be collected than will be delivered to the Laboratory for analysis. Each time an automated sampler is triggered, the Field Manager will coordinate with the OCP Office to assess whether or not the rain event qualifies for submission of the samples for analysis. Coordination on each event will occur such that the sample holding times are not exceeded. Samples not submitted for analysis will be disposed by the Contractor in a manner consistent with State regulations, as determined by the Contractor.

The Contractor will contact the Laboratory to acquire laboratory-supplied sample containers, labels, coolers, and preservatives and will pick-up these supplies at the project laboratory. The Contractor will coordinate with the Laboratory for delivery of samples under Chain of Custody procedures (see Sections 9.6 and 9.7) within 12 hours of sample collection, recognizing that sample collection may occur during non-business hours and on weekends.



7 DOCUMENTATION

Field Documentation Forms will serve as a record of events, measurements, samples collected, and observations during field activities. All information pertinent to monitoring activities should be recorded on Field Documentation Forms and stored sequentially in a Field Log Book, preferably a three-ring binder. Entries on the Field Documentation Forms will include:

• Date;

• Names of field crew;

• Water quality meter identification number;

• Weather conditions (air temperature, cloud cover, precipitation - including the past 24 hours, and snowmelt);

• Monitoring site ID;

• Time;

• Location of measurements and sample collection;

• Field measurement results;

• Number of samples collected;

• Sample identification numbers; and

• Field observations. A Field Documentation Form is included in Appendix A.



8 FIELD MEASUREMENTS

In-stream dissolved oxygen, temperature, pH, and conductivity will be measured using appropriate field instruments. A minimum of one measurement will be taken at each CSO during one of the monitoring events. A measurement will be taken in each discrete sample at each stormwater location for each monitoring event. Table 8-1 lists the parameters, location of measurement at each site, and method of measurement.

Field measurements will be conducted following the Standard Operating Procedures for Field Water Quality Measurements in Appendix B. Field instruments will be calibrated before initiating monitoring activities for each event or at the beginning of each monitoring day. A post-monitoring calibration check will also be conducted at the end of each monitoring day. All calibration and maintenance activities will be documented on the Meter Calibration and Maintenance Log (see Appendix B).

Measurements will be documented on the Field Documentation Form (see Appendix A). Documentation will include: date/time, location, type of measurement, personnel, equipment and associated calibration specifications, and general site observations (e.g., weather conditions).

Meter logs will be faxed to the OCP Office the day following a sampling effort, and a hard copy will be provided to the OCP Office within 4 days following the completion of each monitored event. All documentation, including Field Documentation Forms and Meter Calibration and Maintenance Logs, will be maintained in a field log book for the project.

Table 8-1

Field Measurements

Parameter Location of Measurement Method

Temperature

Conductivity

pH

Dissolved Oxygen

Mid-depth

of flow, as possible

Horiba, Hydrolab,

YSI, or similar meter

Sources of readily available backup monitoring equipment will be identified such that an aborted survey or significantly limited monitoring will be prevented in the case that equipment is damaged, lost or stolen.



Observations will be made at each monitoring location related to weather, flow characteristics, and visual and olfactory characteristics. These observations will be documented on the Field Documentation Form. Table 8-2 summarizes the types of observations that will be made. The field crew is encouraged to take pictures, log them on the Field Documentation Form, and include them in the Field Log Book with appropriate documentation (date, time, location, and noteworthy items).

Table 8-2

Summary of Observations

Observation Description

Floating Debris Type of trash or waste (e.g. sanitary products, beverage containers, etc.)

Visual Characteristics of Flow

Color (colorless, brown, etc) Opacity (clear, cloudy, etc)

Odor Sewage, chlorine, etc.

Depth of flow in pipe/backwater conditions

Flowing full, 1/3 depth, etc.



9

9.1

9.2

9.3

SAMPLE COLLECTION, HANDLING AND DELIVERY

The section outlines procedures for equipment installation, configuration and calibration; sample collection, handling, and delivery; and documentation.

Equipment Installation

Installation of automated sampling equipment in CSO and separate stormwater discharge locations may require entry into confined spaces. Confined space permits must be completed by the Contractor prior to field activities. All field staff entering confined spaces will be properly trained per OSHA requirements. Equipment will be installed per manufacturer’s recommendations and following the standard operating procedure for Automated Sampler Installation and Operation found in Appendix B. Following completion of sampling activities, the Contractor will remove all sampling equipment and repair and restore all sewers and surrounding areas to their condition prior to installation of equipment, as determined by WSD.

Equipment Configuration and Calibration The automated sampling equipment must be properly configured and calibrated for each specific sampling location prior to initiation of sampling activities. The Contractor may coordinate with the flow monitoring contractor when configuring the automated samplers. Automated samplers will be calibrated upon initiation of sampling activities per manufacturer’s recommendations and the calibration recorded in the Field Log Book. Automated samplers will be recalibrated as necessary.

Sample Collection Samples for laboratory analysis of water quality parameters will be collected with automated sampling equipment. As outlined in Section 5 Monitoring Location and Frequency, discrete samples will be collected at CSO sampling locations and separate stormwater discharge sampling locations.

Samples will be retrieved by field crews. The Contractor will coordinate with the OCP Office to determine whether collected samples will be sent to the laboratory for analysis. Sample information will be downloaded using software installed on a laptop computer, using a data transfer unit, or via the keypad on the sampler unit. This information will be stored in the Field Log Book.

All samples will be collected following the standard procedures for Cleaning Equipment and Surface Water Sampling provided in Appendix B. Sample containers provided by the Laboratory will be filled from sampling devices. Filtering of samples for dissolved parameters will be conducted by the



Laboratory. A summary table of the parameters, sample containers, required preservatives, and sample volumes is provided in Table 9-1.

Table 9-1

Parameter List, Sample Containers, Volumes, and Preservatives

Parameters Combined

Sewers Stormwater Container

List Preservative/ Storage

Requirements

Minimum Sample

Volume (mL)

Total Suspended Solids (TSS)

Total Dissolved Solids (TDS)

Volatile Suspended Solids (VSS)

Turbidity

Total Kjeldahl Nitrogen (TKN)

YES YES 1000 mL poly Refrigerate to 4oC 650

Fecal coliform

Escherichia coliform (E. coli) YES YES

250 mL sterilized glass

Refrigerate to 4oC 50

5-day Carbonaceous Biochemical Oxygen Demand (CBOD5)

20-day CBOD (CBOD20) YES YES 1000 mL poly Refrigerate to 4oC 1000

Total Phosphorus (TP)

Dissolved Phosphorus YES YES

250 mL poly (TP)

1000 mL poly (diss-P)

Refrigerate to 4oC

After filtering for the dissolved fraction, preserve both aliquots

with H2SO4 to pH<2

Filtering will be conducted by the Laboratory

100

Ammonia Nitrogen (NH3)

Nitrate + Nitrite (NO3+NO2)

Total Phenolics

Chemical Oxygen Demand (COD)

YES

(except total phenolics and COD)

YES 250 mL poly Refrigerate to 4oC

Add H2SO4 to pH<2 110

Total/Dissolved Metals

Hardness YES YES 1000 mL

Refrigerate to 4oC until filtering is complete. Filtering

will be conducted by the Laboratory. Add HNO3 to

pH<2 to both aliquots (dissolved and total fractions)

250

Total Mercury (Hg) NO YES 1000 mL poly Refrigerate to 4oC

Add HNO3 to pH<2 50

Oil & Grease NO

YES (first discrete sample only)

2 x 1000 mL Glass (wide

Mouth) Add HCl to pH < 2.0 1000

Pesticides

Organic Base Neutral Acids (BNAs) NO YES

3x1 L Glass Amber

None 2000



9.4

9.5

Sample Labeling All samples will be assigned a unique identification code such that all necessary information can be attained from the sample label. Unless an alternative code is approved by the OCP, this code will identify the following:

Label: ___ ___ ___ ___ – ___ ___ ___ – ___ – ___ ___ ___ ___ ___ ___ – ___ ___ ___ ___

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22

Characters 1 – 8: Sample site ID (see Table 5-1)

Character 10: Sample Type, i.e. L = liquid, S = solid, and as assigned

Characters 12 – 17: Date (e.g. September 23, 2004 = 092304)

Characters 19 – 22: Time using 24-hour clock

Example: A discrete liquid sample taken from the separate storm sewer system at SE 50th Terrace & Sterling on September 23, 2004 at 6:00 PM would be identified by the following WQSS–801–L–092304–1800. It is important to note that the dashes shown above count as characters, and must be included in input files.

In addition to the label ID, the sample bottles will be clearly marked using waterproof ink with the following information:

• Client - WSD; • Analyses - List of requested analyses to be performed from the container; • Preservatives - Preservative in the sample container; • Time - Time sample was collected; and • Crew - Crew identification.

Field blank and duplicate sample identifications are slightly different from the routine samples. Unless an alternative is approved by the OCP, the blank and duplicate identification will be in the same form as other samples except that the location ID will be QA-X. QA will designate the sample as a QA/QC sample, X is the QA Sample Number. Date and time should be recorded using the same nomenclature as other samples.

Quality Assurance/Quality Control Samples An important component of the QAPP is the collection and analysis of field Quality Assurance/Quality Control (QA/QC) samples, including field blanks and field duplicates. All QA/QC samples will be collected following the Standard Operating Procedures for Surface Water Sampling in Appendix B.



Field blanks will be used to monitor potential contamination introduced into the samples by collection and handling procedures. The blank will be generated at the sample collection site by filling an empty sampling bottle with deionized, distilled water (provided by the WSD Laboratory) using the same procedure used when transferring the CSO and stormwater samples from the automated samplers to sample bottles. The blank will be returned from the field in a cooler with the regular samples. Field blanks will be collected at a frequency of one per 20 regular samples collected.

Field duplicates will be used to assess the consistency and precision of field sampling and analytical procedures. The duplicate will be collected by simultaneously filling a second sample container from the same source as the first, using identical procedures. The duplicate will be returned from the field in a cooler with the regular samples. Field duplicates will be collected at a frequency of one per every 10 regular samples collected. Duplicates will be collected on a rotating schedule.

9.6

9.7

9.8

Sample Chain of Custody Completed Chain of Custody documents will be required for all samples delivered to the laboratory for analysis. Chain of Custody documents will be initiated by the sampling crews in the field during the sampling events. The Chain of Custody document will contain the sample’s unique identification number, sample date and time, sample description, sample type, sample preservation, and analyses required. The Chain of Custody documents will remain with the samples and in the possession of the sampling crew. The original signed Chain of Custody document will accompany the samples to the laboratory. A Chain of Custody document is included in Appendix C.

Handling and Delivery Samples will be handled and transported following the Standard Operating Procedures for Sample Handling and Delivery in Appendix B. Filled sample containers will be stored in coolers on ice at 4 degrees Celsius throughout conveyance and delivery to the laboratory. Samples will be delivered to the laboratory within 12 hours of sample collection.

Field Records and Documentation Field Documentation Forms will be faxed (or emailed), along with completed Chain of Custody forms, to the OCP Office at the beginning of each day following sampling. Hard copies of the Field Documentation Form and the Chain of Custody forms will be delivered to the OCP Office within 4 days of completing each sampling event and also maintained in the Field Log Book for the project.



Appendix A Field Documentation Form

CSO-SW_Sampling_Plan_060905_Rev1.doc REV1 FINAL 6/09/2005 A-1


Field Documentation Form Date: ____________________ Field Crew: Water Quality Meter ID#:___________________ Air Temperature:_________________ F or C (circle one)

Cloud Cover: none light moderate heavy (circle one)

Precipitation: none light moderate heavy snow (circle one)

Precipitation in last 24 hours: yes no (circle one)

Snowmelt: none light moderate heavy (circle one)

Site ID: Time:

Measurement/sampling location

Required Field Measurements

Temperature

(F or C) Conductivity

(µS/cm) pH D.O.

(mg/L)

Results (specify units)



Sample Collection Results

Samples collected Sample ID

If field blank collected,

Sample ID

If field duplicate collected,

Sample ID Total Suspended Solids (TSS)

Total Dissolved Solids (TDS)

Volatile Suspended Solids (VSS)

Turbidity Total Kjeldahl Nitrogen (TKN) Fecal coliform Esherichia coliform (E. coli) 5-day Carbonaceous Biochemical

Oxygen Demand (CBOD5) 20-day CBOD (CBOD20) Total Phosphorus (TP) Dissolved Phosphorus Ammonia Nitrogen (NH3)

Nitrate + Nitrite (NO3+NO2) Total Phenolics Chemical Oxygen Demand (COD) Total/Dissolved Metals

Hardness

Total Mercury (Hg)

Oil & Grease Pesticides Organic Base Neutral Acids (BNAs)

Field observations

Floating or submerged debris?

Visual Characteristics of Flow?

Odor? Depth of flow in pipe/backwater

conditions? Noteworthy comments

or pictures



Appendix B Standard Operating Procedures

CSO/Stormwater Sampling Page B-2 Field Water Quality Measurements Page B-5 Sample Handling and Delivery Page B-7 Equipment Cleaning Page B-9

CSO-SW_Sampling_Plan_060905_Rev1.doc REV1 FINAL 6/09/2005 B-1


CSO/Stormwater Sampling 1 Introduction

This standard operating procedure (SOP) is applicable to the collection of representative liquid samples, both aqueous and non-aqueous, from sewers, streams, rivers, lakes, ponds, lagoons, and surface impoundments. It includes samples collected from depth, as well as samples collected from the surface. These typically applicable procedures have been adapted from the U.S. EPA Surface Water Sampling SOP No. 2013, dated 11/17/94 and may be varied or changed as required, dependent upon site conditions or equipment and procedural limitations. The actual procedures used should be documented in the field notes, especially if changes are made. There are two primary interferences or potential problems with representative water sampling. These include cross contamination of samples and improper sample collection. Following proper decontamination procedures and minimizing disturbance of the sample site will eliminate these problems as follows:

• Cross contamination problems can be eliminated or minimized through the use of dedicated sampling equipment. If this is not possible or practical, then decontamination of sampling equipment is necessary. Refer to the Equipment Cleaning SOP.

• Improper sample collection can involve using contaminated equipment, disturbance of the stream or impoundment substrate, and sampling in an obviously disturbed area.

2 Materials

The following materials shall be available, as required, during sampling. Back-up field instruments/equipment should be available, if required.

• Personal protective equipment (as required by the Health and Safety Plan); • Cleaning equipment (as required in the Standard Operating Procedure for Equipment Cleaning); • Appropriate sampling apparatus and accessories; • Appropriate sample bottles, preservatives (if required) and sample bottle labels; • Ziploc™-type bags; • Insulated coolers, ice, and appropriate packing material; • Chain of Custody (COC) records and custody seals; and • Field documentation forms, field log book, waterproof pen, camera and film.

3 Preparations

• Determine the extent of the sampling effort, the sampling methods to be employed, and the types and amounts of equipment and supplies needed.

• Obtain the necessary sampling and monitoring equipment to suit the task. Consider sample volume, depth, deployment circumstances (e.g. sewer configuration), types of sample, sampler composition materials, and analyses to be conducted.



• Decontaminate or pre-clean equipment and ensure that it is in working order. • Prepare scheduling and coordinate with staff, OCP Office, Laboratory, and WSD, if appropriate. • Perform a general site survey prior to site entry, in accordance with the site specific Health and

Safety Plan. 4 General Sample Collection Procedures

1. Record pertinent data on the Field Documentation form. 2. Label all sample containers with the date, time, site location, field crew, and other requested

information. 3. Don appropriate personal protective equipment (as required by the Health and Safety Plan). 4. Clean all sampling equipment prior to sample collection according to the procedures in the

Standard Operating Procedure for Equipment Cleaning. 5. If field preservation is required, place appropriate preservative into the sample container prior to

sample collection. Note the preservative and preservative column on the sample container and sampling log.

6. If any quality control samples are specified in the work plan, they will be collected in the following manner:

• Duplicate samples should be collected at the same time or immediately following one another in accordance with the above procedures;

• Trip blanks should be prepared by the laboratory and shipped with the sample bottles; Trip blanks are not to be opened at any time, except by the laboratory for analysis, and must accompany the other samples/sample bottles at all times. Be sure to log the trip blank samples on the COC before shipping samples back to the laboratory; and

• Field blanks, such as samples of water or reagents used to clean sampling equipment, should be collected directly into the sample bottle from the appropriate sampling device.

7. Record sample collection information on the Field Documentation Form and store the samples in an iced cooler as described in the Standard Operating Procedure for the Handling and Delivery of Samples.

8. Handle, pack, and deliver samples according to the procedures in Standard Operating Procedure for the Handling and Delivery of Samples.

5 Equipment-Specific Sample Collection Procedures

Characterization of combined sewer and separate stormwater discharges may require the collection of water quality samples directly from the sewer systems. Sampling methods that allow access to difficult to reach and potentially unsafe conditions may be required. Two acceptable methods are described below. The contractor should consult the objectives of the CSO/stormwater sampling plan and use their best professional judgment to insure that the sampling method selected meets all project needs, QAPP objectives, and HASP guidelines.



a) Automated Sampler Installation and Operation - CSO and stormwater samples may be collected

using automated samplers. The automated sampling equipment must be properly configured and calibrated for each specific sampling location prior to initiation of sampling activities. Proper configuration includes developing an understanding of the flow characteristics of each sampling location (for appropriate routine initiations and volumes of flow-weighted composite samples), calibration of flow monitoring devices, and testing programmed sampling protocols. Equipment will be installed and calibrated per manufacturer’s recommendations. The calibration will be recorded in the Field Log Book. For samples collected with an automatic sampler, follow these procedures: 1. Using adequate protective equipment, access the sampling station by appropriate means. 2. Review all sample containers for appropriate size and preservative. 3. Follow manufacturer’s instructions for specific guidance in using an automatic sampler. 4. Ensure that the intake is positioned such that water will be drawn during the entire sampling

period but that sediment will not 5. Fill storage space with ice, if possible. 6. Program sampler to collect samples according to the sampling plan. 7. Label and preserve the sample containers and complete all documentation.

b) Dip Sampler - A dip sampler is useful in situations where a sample is to be recovered from locations (e.g., outfall pipe, sump manhole, along a pond or lagoon bank) where direct access is limited. The long handle (or line if sampling from a bridge or other structure directly above the water body) on such a device allows access from a safe location. Sampling procedures are as follows: 1. Assemble the device in accordance with the manufacturer’s instructions. 2. Extend the device to the sample location and collect the sample by dipping the sampler into

the substance. 3. Retrieve the sampler and transfer the sample to the appropriate sample container.

6 Safety Advanced planning can eliminate many safety hazards. For safety reasons, all sampling should occur in pairs. If possible, the sampling crew should carry a cellular phone or other communication device, an emergency contact list, and carry basic safety equipment. The crew should be aware of potential hazards at a monitoring site and any change in weather conditions. More detailed safety information can be found in MEC Water Resources’ Health and Safety Plan.



Field Water Quality Measurements

1 Introduction

Water quality parameters, such as dissolved oxygen, specific conductance, pH, and temperature, may be measured in the field during CSO/stormwater monitoring. These parameters may be measured using individual or multi-sensor probes, as available and appropriate for each situation. The Meter Calibration and Maintenance Log is included as an attachment to this Standard Operating Procedure. 2 Materials

The following materials, as required, shall be available during field measurement of water quality: • Personal protective equipment (as specified in the Health and Safety Plan); • Temperature, pH, conductivity, and dissolved oxygen meters, as required; • Manufacturer's operating manuals for each instrument; • Calibration solutions appropriate for each instrument; • Tools necessary for field maintenance of instruments; • Extra batteries for the meters; • Cleaning materials (as required in the Standard Operating Procedure for Equipment Cleaning);

Distilled/deionized water; and • Appropriate forms and field notebook.

3 Procedures for Field Water Quality Measurements

1. Calibrate and operate all meters in accordance with manufacturer’s operating manuals. Record calibration in the Meter Calibration and Maintenance Log attached.

2. Setup instruments and take in-situ surface water measurements by placing meter probes at the designated location in the water body. Temperature, pH and conductivity measurements may be taken from samples collected with the automatic samplers.

3. Measure and record the meter readings for each parameter:

• Allow instrument readings to stabilize before recording, as appropriate.

4. Rinse probes off in distilled/deionized water, if required.

5. Log results and observations in Field Documentation Form.



METER CALIBRATION AND MAINTENANCE LOG Temperature, pH, Conductivity, Dissolved Oxygen And Turbidity Meters Instrument Temperature pH Conductivity D.O. Turbidity Manufacturer Model Identification No.

Date Time Initials Temp pH Conductivity D.O. Turbidity Battery Comments

°C 4 7 10 Std: ______ µS/cm

Std: ______ NTU

Check



Sample Handling and Delivery

1 Introduction

This standard operating procedure (SOP) is applicable to the handling and delivery of samples collected in the field. Sample handling and delivery is conducted using sample tracking systems and Chain of Custody procedures that properly identify samples and ensure the control of those samples from the field through laboratory analysis. The procedures outlined in this SOP are generally applicable to any sampling activity, and may be varied or changed as required, dependent upon site conditions or equipment and procedural limitations. The actual procedures used should be documented in the field notes, especially if changes are made.

2 Labeling

All samples will be assigned a unique identification code such that all necessary information can be attained from the sample label. Refer to the Sampling Plan for specifics on the identification code. In addition to the label ID, the sample bottles will be clearly marked using waterproof ink with the following information:

• Client – WSD;

• Analyses – List of requested analyses to be performed from the container;

• Preservatives – Preservative in the sample container;

• Time – Time sample was collected, and

• Crew – Crew identification. Field blank and duplicate sample identifications are slightly different from the routine samples. Unless an alternative code is approved by the OCP, the blank and duplicate identification will be in the same form as other samples except that the location ID will be QA-X. QA will designate the sample as a QA/QC sample; X is the QA Sample Number. Date and time should be recorded using the same nomenclature as other samples.

3 Handling and Delivery

Filled sample containers will be stored in coolers on ice at 4 degrees Celsius throughout conveyance and delivery to the laboratory. Samples and coolers will be packaged appropriately for shipment. Samples will be delivered to a designated custodian at the laboratory within 12 hours of sample collection. Completed Chain of Custody documents will be required for all samples delivered to the laboratory for analysis. The field sampling crews will prepare the Chain of Custody documents during or directly after the sampling events. The Chain of Custody document will contain the sample:

• Unique identification number;

• Date and time;



• Sample description;

• Sample type;

• Sample preservation, and

• Analyses required. The Chain of Custody documents will remain with the samples and in the possession of the sampling crew. The original signed Chain of Custody document will accompany the samples to the laboratory. A copy of the COC will be retained for field documentation. A Chain of Custody document is included in Appendix C of the Sampling Plan.



Equipment Cleaning

1 Introduction

The equipment cleaning procedures described in this document include pre-field, in-field, and post-field cleaning of sampling equipment. The sampling equipment may consist of sampling devices; field instruments; or other activity-specific sampling equipment. All non-disposable sampling equipment will be cleaned after completion of each sampling event. 2 Materials

The following materials will be available during equipment cleaning, as needed: • Personal protection equipment (as required in the Health and Safety Plan); • Distilled/deionized water; • Non-phosphate detergent (e.g. Liquinox or equivalent); • Tap water; • Wash basins (e.g. 5-gallon pails); • Brushes; • Aluminum foil; • Large heavy-duty garbage bags; • Spray bottles (to hold tap water and distilled/deionized water); and • Disposable and/or heavy-duty reusable (PVC, latex or nitrile) gloves.

3 Storage of Equipment

All cleaned sampling equipment will be stored in a clean environment and, if appropriate, the equipment will be covered/sealed with aluminum foil. 4 Field Cleaning Procedures

a) Cleaning of Sample Collection Devices - Cleaning of sampling equipment will be conducted according to the following sequential procedure: • Non-phosphate detergent (e.g. Liquinox or equivalent) and tap water scrub; • Tap water rinse; and • Triple distilled/deionized water rinse.

The first step, non-phosphate detergent and tap water scrub, is intended to remove all visible particulate matter and residual oil and grease. The tap water rinse is necessary to remove all soapy residues. The final rinse of distilled/deionized water will be repeated three times.

b) Collection and Disposal of Rinse Solutions - All rinse waters generated during the cleaning of

equipment on-site will be collected, containerized, and disposed of in a sink or spread on a vegetated area away from streams.



Appendix C Chain of Custody Document

NOTE: This Chain of Custody form is provided as an example. A project-specific form will be created

by the Contractor once sample labeling and container lists are finalized.

CSO-SW_Sampling_Plan_060905_Rev1.doc REV1 FINAL 6/09/2005 C-1


CSO-SW_Sampling_Plan_060905_Rev1.doc REV1 FINAL 6/09/2005 C-2

Kansas City, Missouri Water Services Department


Water Quality Monitoring

Quality Assurance Project Plan April 14, 2005

City Contract 770 – City Project 8100148

Quality Assurance Project Plan Kansas City, Missouri Water Services Department

Quality Assurance Project Plan

For the Kansas City, Missouri Water Services Department


Water Quality Monitoring

Revised: April 14, 2005

Adopted by: Date:

Title:

Adopted by: Date:

Title:

Adopted by: Date:

Title:

Adopted by: Date:

Title:

QAPP_041405_Final.doc FINAL 4/14/2005


Table of Contents

1 INTRODUCTION...............................................................................................................................1-1 1.1 Purpose..........................................................................................................................................1-1 1.2 Scope and Schedule ......................................................................................................................1-2

2 MANAGEMENT ................................................................................................................................2-1 2.1 Organization..................................................................................................................................2-1 2.2 Roles and Responsibilities ............................................................................................................2-2

2.2.1 Administrator ......................................................................................................................2-2 2.2.2 Project Manager ..................................................................................................................2-3 2.2.3 QA/QC Manager .................................................................................................................2-3 2.2.4 Project Staff.........................................................................................................................2-4

3 DATA GENERATION AND ACQUISITION...................................................................................3-1 3.1 Data Quality Objectives and Criteria Control...............................................................................3-1 3.2 Sampling Methodology.................................................................................................................3-1

3.2.1 Sample Collection ...............................................................................................................3-1 3.2.2 Field Water Quality Measurements and Monitoring...........................................................3-2 3.2.3 Cleaning of Equipment and Materials.................................................................................3-2

3.3 Sample Handling and Custody......................................................................................................3-2 3.3.1 Field Sample Custody .........................................................................................................3-2 3.3.2 Laboratory Sample Custody................................................................................................3-3

3.4 Analytical Methodology ...............................................................................................................3-4

4 DATA ASSESSMENT AND OVERSIGHT ......................................................................................4-1 4.1 Field Measurement Procedures.....................................................................................................4-1 4.2 Sample Collection.........................................................................................................................4-1 4.3 Laboratory Procedures ..................................................................................................................4-1

4.3.1 SOP/SAP Requirements......................................................................................................4-2 4.3.2 Laboratory Measurements...................................................................................................4-2

4.4 System Audits and Technical Reviews.........................................................................................4-2 4.5 Corrective Action..........................................................................................................................4-3

5 DATA REVIEW, VERIFICATION, VALIDATION AND USABILITY .........................................5-1 5.1 Data Review..................................................................................................................................5-1 5.2 Data Verification...........................................................................................................................5-1 5.3 Data Validation .............................................................................................................................5-2 5.4 Data Usability ...............................................................................................................................5-4

QAPP_041405_Final.doc FINAL 4/14/2005 TOC-1


6 DATA MANAGEMENT ....................................................................................................................6-1 6.1 Field Data and Information Management .....................................................................................6-1 6.2 Laboratory Data and Information Management............................................................................6-1 6.3 Electronic Data Management........................................................................................................6-2

LIST OF TABLES Table 2-1 Roles and Responsibilities.....................................................................................................2-2 Table 5-1 Data Validation Qualifiers.....................................................................................................5-3 LIST OF FIGURES Figure 2-1 Management Organization Chart ..........................................................................................2-1 APPENDICES Appendix A – Data Quality Objectives and Criteria Control



LIST OF ACRONYMS

CSO Combined Sewer Overflow DQO Data Quality Objectives HASP Health and Safety Plan KCMO Kansas City, Missouri MS Matrix Spike MSD Matrix Spike Duplicate OCP Overflow Control Program QAPP Quality Assurance Project Plan QA/QC Quality Assurance/Quality Control RDL Required Detection Limits RPD Relative Percent Difference RW Receiving Water SAP Standard Analytical Procedure SOP Standard Operating Procedure SWO Storm Water Outfall U.S. EPA United States Environmental Protection Agency WSD Water Services Department



1

1.1

INTRODUCTION

The Kansas City, Missouri (KCMO) Water Services Department (WSD) is committed to protecting public health and the environment, meeting water quality regulations and doing so at an appropriate cost. To accomplish this mission, an Overflow Control Program (OCP) has been established within the WSD.

Credible data on the water quality in streams, rivers and lakes in KCMO and the pollutant sources impacting these water bodies are essential to efforts to carry out the WSD mission. Therefore, WSD and its contractors will conduct water quality monitoring activities to characterize the existing conditions, evaluate the benefits and costs of efforts to protect or improve water quality, and track changes in water quality over time.

This Quality Assurance Project Plan (QAPP) addresses the proper execution of water quality monitoring activities by WSD and its contractors to ensure that the resulting data is useful, reliable and credible. The requirements of this QAPP are applicable to the activities of all participants involved, including WSD staff and contractors. Individuals responsible for conducting water quality monitoring activities should review, become familiar with, and conduct activities in accordance with the requirements of this QAPP.

Purpose

The purpose of the QAPP is to assure that:

• Sample collection and field measurements are conducted at planned frequencies and locations using appropriate sampling protocols and equipment;

• Samples are properly handled in the field and delivered to the laboratory, using appropriate sample bottles, labels, and preservatives;

• Sample handling and delivery is conducted using sample tracking systems and Chain of Custody procedures that properly identify samples being collected and ensure the control of those samples from field collection through analysis and data reduction;

• Proper preventive maintenance, equipment calibration, and approved analytical protocols will be implemented so that all field measurements and sampling analytical results will be valid;

• Records are produced and retained to document the quality of samples collected and analyzed, the validity of applied procedures, and the completeness of the investigation in relation to the approved scope of the project;

• Generated data are validated; and

QAPP_041405_Final.doc FINAL 4/14/2005 1-1


• Calculations, evaluations, and decisions completed or deduced based on the results of the monitoring activities are accurate, appropriate, and consistent with the objectives of the water quality monitoring activities.

This QAPP has been developed based on guidance in the following documents:

United States Environmental Protection Agency (EPA), December 2002. EPA Guidance for Quality Assurance Project Plans, EPA QA/G-5. Washington, DC.

United States Environmental Protection Agency (EPA), November 2002. Guidance on Environmental Verification and Data Validation. EPA QA/G-8. Washington, DC.

1.2 Scope and Schedule

The QAPP is organized into the following major sections:

• Management;

• Data Generation and Acquisition;

• Data Assessment and Oversight;

• Data Review, Verification, Validation and Usability; and

• Data Management.

Sampling Plans have been developed for separate and distinct monitoring programs. Information contained in the Sampling Plans includes:

• Monitoring Objective;

• Quality Assurance Project Plan (QAPP);

• Health and Safety Plan;

• Monitoring Team;

• Monitoring Location and Frequency;

• Coordination and Initiation of an Event;

• Documentation;

• Field Measurements; and

• Sample Collection, Handling and Delivery.



This QAPP addresses quality assurance activities necessary to achieve the objectives outlined in the following Sampling Plans:

• WSD Routine Water Quality Monitoring of CSO Receiving Waters, Final Draft, Dated December 16, 2004;

• Overflow Control Program, Receiving Water Sampling Plan, April 14, 2005; and

• Overflow Control Program, CSO/Stormwater Sampling Plan, April 14, 2005.

Each Sampling Plan refers to this QAPP and requires that all activities described in the Sampling Plan must be conducted in accordance with this QAPP. Changes to the above Sampling Plans or the development of additional Sampling Plans require that this QAPP be reviewed and revised, as needed, to assure that the resulting data is useful, reliable and credible. Health and safety procedures for activities associated with each Sampling Plan are described in separate Health and Safety Plans.

The schedule for monitoring activities is defined in each specific Sampling Plan. WSD will assess the monitoring frequency and duration as the monitoring proceeds and will make adjustments necessary to accommodate specific objectives or suspend/terminate monitoring. Proposed changes to monitoring schedules must be reviewed and approved by WSD before being implemented.



2

2.1

MANAGEMENT

The KCMO WSD and the Overflow Control Program (OCP) Office are responsible for the development and oversight of individual Sampling Plans and this QAPP. WSD staff and sampling contractors will execute the Sampling Plans and QAPP, and will maintain the technical responsibility for implementing the water quality sampling activities accordingly. The WSD laboratory and contracted laboratories are responsible for all laboratory analytical testing associated with the Sampling Plans and will perform analyses in accordance with this QAPP. WSD staff, OCP staff, and contractor staff have the responsibility for performance of assigned quality control duties in the course of accomplishing identified sampling and analysis activities. The quality control duties include:

• Completing the assigned activity on or before schedule and in a quality manner in accordance with protocols in the Sampling Plans and this QAPP; and

• Ascertaining that the work performed is technically correct and meets all aspects of the Sampling Plans and QAPP.

Organization

The proposed management organization is presented in Figure 2-1. All contractors will report directly to the OCP Office. Additionally, laboratory staff will maintain a reporting relationship with sampling staff.

Figure 2-1

Management Organization Chart

Kansas City, Missouri Water Service Department (WSD)

Overflow Control Program (OCP) Office

WSD Sampling Staff

WSD Laboratory

Sampling Contractor

Laboratory Contractor



2.2 Roles and Responsibilities

A variety of professional, field, and laboratory staff will be involved in the various monitoring programs. WSD, the OCP Office, and each contractor are responsible for assigning duties based on individual staff qualifications. Training sessions will be conducted by each entity, when needed, for their respective staff. Each entity will also provide staff copies of the Sampling Plan, the Laboratory Standard Operating/Analytical Procedure (SOP/SAP), and the Health and Safety Plan (HASP) prior to commencing work. Responsibilities for key roles are summarized in Table 2-1.

Table 2-1 Roles and Responsibilities

Entity Role General Responsibilities KCMO WSD Administrator General oversight and review/approval of

all work products. OCP Administrator (Coordinator)

General oversight and review/approval of all work products.

OCP Project Manager (Technical Coordinator)

Liaison to the Contractors. Oversees all data evaluation and reporting activities

OCP Office

OCP QA/QC Manager (LimnoTech, Inc.)

Independent review and data validation. Performs audits of sampling and laboratory activities.

Sampling and Laboratory Project Managers

Liaison to other entities. Oversees all sampling, analysis, data evaluation, and reporting activities.

Sampling and Laboratory QA/QC Managers

Reviews and validates sampling and laboratory activities.

WSD Sampling Staff, WSD Laboratory, and Sampling and Laboratory Contractors Sampling and Laboratory

Project Staff Performs all sampling and analysis, quality assurance, data evaluation, and reporting activities.

2.2.1 Administrator

The OCP Administrator will retain general oversight of the Sampling Plans and QAPP. The Administrator will review all work products produced.



2.2.2

2.2.3

Project Manager

The Sampling and Laboratory Project Managers are responsible for the overall administration and staffing of the monitoring activities and for maintaining a clear definition of and adherence to the scope and schedule. These Project Managers will also oversee all activities and brief their staff on QA/QC issues and the Health and Safety protocol. As a part of this responsibility, the Project Managers will:

• Direct activities as defined in the Sampling Plans and QAPP;

• Approve reports and other materials for release to the Administrators;

• Serve as the point of contact for team members and liaison to other entities;

• Perform final review of data reductions, report submittals, and presentations;

• Assure corrective actions are taken for deficiencies noted during project activities;

• Maintain schedule surveillance;

• Provide training when needed;

• Maintain all documentation for at least 3 years; and

• Assist the Quality Assurance/Quality Control (QA/QC) Manager in reviewing and validating the data generated to assure all data quality objectives have been met.

QA/QC Manager

The QA/QC Manager is responsible for the overall quality assurance and control aspects of the monitoring activities. As a part of this responsibility, the QA/QC Manager will:

• Provide for QA/QC management of all aspects of the Sampling Plans and QAPP;

• Notify the appropriate parties if inconsistencies or errors are found in the data;

• Review and validate data generated to assure all data quality objectives are met;

• Ensure that staff adhere to the standard operating and analytical procedures (SOP/SAP) for each constituent, and that all samples are handled in accordance with standard procedures; and

• Review and validate the data generated to assure all data quality objectives are met.



2.2.4 Project Staff

The Project Staff are responsible for the implementation of sampling and analysis activities, initial data acquisition, health and safety aspects of monitoring activities, and for the proper selection and execution of procedures that have been accepted for use in the investigation as defined in the Sampling Plan, QAPP, and Health and Safety Plan. Project staff will:

• Perform data gathering and compilation tasks;

• Review the collection of samples to ensure representation of field conditions;

• Perform maintenance of equipment to prevent equipment failures and project delays;

• Review the effectiveness of procedures and suggest changes that will enhance or more efficiently accomplish the objectives of the Sampling Plans;

• Assist in maintaining the schedule;

• Perform analytical procedures;

• Strictly adhere to all protocols in the Sampling Plans, QAPP, and HASP; and

• Prepare and review appropriate documentation related to monitoring activities.



3

3.1

3.2

3.2.1

DATA GENERATION AND ACQUISITION

The sampling process design is presented in the individual Sampling Plans, including sampling rationale, strategies, locations, media, frequencies, and schedules. The following sections outline the data quality/criteria, sampling methodology, sample handling and custody, and the analytical methodology.

Data Quality Objectives and Criteria Control

Data quality will be measured in terms of accuracy, precision, completeness, representativeness, comparability, and required detection limits for the analytical methods. Definitions of each measure are provided below. A detailed explanation of each measure is provided in Appendix A.

• Accuracy is the measure of the agreement between an observed value and an accepted reference value or true value;

• Precision is a measure of the agreement between two or more measurements;

• Completeness is a measure of the amount of valid data obtained from the monitoring program compared to the amount of data that was expected;

• Representativeness is the degree to which data accurately and precisely represent a characteristic of a population, parameter variations at a sampling point, a process condition, or an environmental condition; and

• For the analytes specified for this study, all the required detection limits (RDL) are at the usual contract laboratory detection limits.

Sampling Methodology

Sampling protocols will be employed to provide consistency and reproducibility to the sampling methods used by field personnel. For all sampling related procedures, personnel will use personal protective equipment as required by the HASP.

Sample Collection

Samples will be collected as specified in the Sampling Plan. The Sampling Plan describes the methodology, equipment, technique, and other sampling-related information.



3.2.2

3.2.3

3.3

3.3.1

Field Water Quality Measurements and Monitoring

Instantaneous water quality measurements (such as dissolved oxygen, temperature, etc.) using field instruments will be collected as specified in the Sampling Plan. In-situ monitoring instruments and equipment will be installed in a manner consistent with work plan specifications and using methods that incorporate the unique requirements of specific locations. Maintenance, cleaning and/or data download activities for in-situ instruments will be performed at a frequency necessary to assure that representative data is generated and all generated data is recorded. Data quality objectives for field measurements are presented in Appendix A.

Cleaning of Equipment and Materials

All reusable grab sampling equipment and materials used during the field activities will be cleaned prior to use and at specified intervals during the field activities. Cleaning will be performed according to the procedures specified in the Sampling Plan.

Sample Handling and Custody

Sample handling and custody procedures will be performed as specified in the Sampling Plans. Field and laboratory sample custody are briefly explained in the following subsections.

Field Sample Custody

The objective of field sample custody is to assure that samples are traceable and untampered with between sample collection and receipt by the analytical laboratory. A person will have custody of a sample when the samples are:

• In their physical possession;

• In their view after being in their possession;

• In their personal possession and secured to prevent tampering;

• In a restricted area accessible only to authorized personnel; and

• The person is one of the authorized personnel.



Field custody documentation will consist of both field logbooks and Chain of Custody forms.

a) Chain of Custody Forms - Completed Chain of Custody forms will be required for all samples to be analyzed. Chain of Custody forms will be filled-out by the field sampling crew during the sample collection events. The Chain of Custody form will contain the:

• Sample unique identification number;

• Sample date and time;

• Sample description;

• Sample type;

• Sample preservation (if any); and

• Analyses required.

The original Chain of Custody form will accompany the samples to the laboratory. Copies will be made prior to shipment for separate field documentation. The Chain of Custody form will remain with the samples at all times. The samples and signed Chain of Custody form will remain in the possession of the sampling crew until the samples are delivered to the laboratory. Use of the Chain of Custody form may terminate when laboratory personnel receive the samples, sign the form, and enter the samples into the laboratory tracking system. Any discrepancy between the received samples and the Chain of Custody form will be reported to the laboratory Project Manager. The Laboratory shall fax or email the completed Chain of Custody and any noted discrepancies, documentation of broken bottles that are received, and/or any other issues related to sample receipt that may compromise the completion of analytical testing to the OCP Office prior to initiating sample analysis.

3.3.2 Laboratory Sample Custody

Laboratory sample custody will be performed in accordance with QA/QC procedures described in the Laboratory Quality Assurance Program Plan (QA Manual) and this QAPP.

The laboratory must have written standard operating and analytical procedures (SOP/SAP) for custody including sample receipt and maintenance of custody, sample storage, and sample tracking. A description of the QA Manual and SOP/SAP requirements are outlined in Section 4.3. Specific SOP/SAP custody requirements are also indicated in the following sections.

a) Sample Receipt and Maintenance of Custody - The laboratory will have a designated sample custodian responsible for receipt of samples, and will have written SOPs describing duties and responsibilities.



The laboratory will have written SOPs for receiving and logging in of the samples. The procedures will include but not be limited to documenting the following information:

• Condition of coolers, including the presence of ice;

• Presence or absence of Chain of Custody forms;

• Presence or absence of custody seals on shipping and/or sample containers and their conditions, and evidence of leakage;

• Presence or absence of sample labels;

• Sample label identification numbers if not recorded on the Chain of Custody record(s) or packing list(s);

• Condition of the sample bottles;

• Verification of agreement or non-agreement of information on receiving documents, and

• Resolution of problems or discrepancies.

Any abnormal situations will be reported to the laboratory Project Manager, and corrective actions will be taken.

b) Sample Storage - After samples are received, they will be placed in secure storage (e.g., locked refrigerators) and maintained at 4 degrees Celsius. The laboratory will have written SOPs for maintenance of the security of samples after receipt and will demonstrate security of the sample storage and laboratory areas. The SOPs will specifically include descriptions of all storage areas for samples in the laboratory, and steps taken to prevent sample contamination. Only authorized personnel should have access or keys to secure storage areas.

c) Sample Tracking - The laboratory will have written SOPs for tracking the work performed on any particular sample. Documentation of sample receipt, sample storage, sample transfers, sample preparations, sample analyses, instrument calibration and other QA/QC activities will be performed. These SOPs are included in the laboratory QA Manual.

3.4 Analytical Methodology

The Sampling Plan lists the analytical methods to be used by the laboratory and includes information on the required container type, sample volume, preservation, and holding time for each parameter. The laboratory will provide sample containers and coolers. All sample containers will be new and/or pre-cleaned (and sterilized for bacteria sample containers). In addition, the laboratory will provide sample labels for each bottle and provide the required preservative for each parameter, where specified.



The laboratory will conduct the analyses required under each sampling program in accordance with the analytical methods specified in the sampling plans and their internal Standard Analytical Procedures (SAPs).

The laboratory analytical data results and intra-laboratory QA/QC results will be submitted to KCMO WSD or OCP Office Project Manager within the time frame specified in the laboratory analytical services contract.



4

4.1

4.2

4.3

DATA ASSESSMENT AND OVERSIGHT

Internal quality control checks are performed to ensure that the field and laboratory generated measurements meet the project quality assurance objectives. In addition, the quality control checks are intended to identify any need for corrective action. The QA/QC Managers are responsible for the quality control checks and corresponding corrective actions. All quality control documents will be retained in the project files.

Field Measurement Procedures

Field measurement procedures are provided in the Sampling Plan. Field instrumentation and equipment testing, inspection, maintenance, and calibration will follow manufacturer instructions and procedures described in the Sampling Plan. In order to maintain field precision and accuracy, the water quality instruments will be calibrated to known standards at the beginning and conclusion of monitored events. Any problems with sensors will be addressed immediately. At the conclusion of each monitored event, all calibration sheets will be reviewed by the sampling QA/QC Manager to assess the adequacy of the quality control checks and to review instrument performance to identify any problems. The result of each review will be recorded on the instrument calibration sheet or field documentation form.

Sample Collection

Field quality control checks of sample collection activities will consist of QA/QC samples that will be collected or prepared by the field staff for laboratory submittal and analysis. These samples will consist of duplicates and field blanks. The frequency of QA/QC sampling is specified in the Sampling Plan and the acceptable control limits are specified in Appendix A. Upon receipt of the data from a monitored event, the OCP QA/QC Manager will assess the adequacy of the quality control checks and identify any problems.

Laboratory Procedures

Laboratory procedures for analytical services will be conducted in accordance with the Laboratory Quality Assurance Program Plan (QA Manual), the SOP/SAPs and the individual method requirements. The laboratory will submit the QA Manual for review by KCMO WSD or the OCP Office. The QA Manual addresses the laboratory’s method-specific accuracy and precision windows, method detection limits, calibration and verification requirements, instrument maintenance, analyst training, laboratory certifications and performance evaluations and other QA/QC issues affecting the analysis of samples.



4.3.1

4.3.2

4.4

SOP/SAP Requirements

The laboratory must have written standard operating and analytical procedures (SOP/SAP) for custody, laboratory safety, cleaning of analytical glassware, and traceability of standards used in sample analysis QA/QC.

A SOP is defined as a written narrative step-wise description of laboratory operating procedures including examples of laboratory documentation. The SOPs must accurately describe the actual procedures used in the laboratory, and copies of the written SOPs will be available to the appropriate laboratory personnel. These procedures are necessary to ensure that analytical data produced are acceptable for use. The laboratory SOPs will provide mechanisms and documentation to meet the specification of the following sections.

A SAP is defined as a written narrative step-wise description of laboratory analytical procedures for a given method and includes examples of laboratory documentation. The SAPs must accurately describe the actual procedures used in the laboratory, and copies of the written SAPs will be available to the appropriate laboratory personnel. These procedures are necessary to ensure that analytical data produced are acceptable for use and ensure consistency in procedures between sample delivery groups.

The SOP/SAPs used in this monitoring program are included as a separate Appendix in the Laboratory QA Manual.

Laboratory Measurements

Quality control checks will include replicates, matrix spikes, matrix spike duplicates, control samples, and method blanks as appropriate. The acceptable control limits are discussed in Appendix A. The laboratory quality control check frequencies are outlined in the laboratory's QA Manual and SAP, but typically conducted at a frequency of 1 per 10 or 1 per 20 samples taken, depending on the analysis.

Instrumentation and equipment testing, inspection, maintenance, and calibration will follow manufacturer instructions and accepted procedures associated with the selected analytical methods and the laboratory's QA Manual and SOP/SAPs. Supplies and consumables for laboratory activities will be inspected by the laboratory Project or QA/QC Manager prior to use.

At the conclusion of each monitored event, the laboratory QA/QC Manager will prepare a summary of QA/QC results. The OCP QA/QC Manager will review the QA/QC summary to assess the adequacy of the quality control checks and to identify any potential problems.

System Audits and Technical Reviews

The primary responsibility for the quality of work products rests with the individuals doing the work and with their immediate supervisors. For certain project components, it may be necessary for an independent technical reviewer to audit or review the work products. This reviewer may be a team member not directly involved with the work being audited. The independent technical reviewer performs a critical,



written evaluation of the work product, and the independent technical audit or review is then incorporated in the project record.

KCMO WSD and OCP Office is responsible for identifying the work products to be audited/reviewed and the scope of the audit/review, for scheduling independent technical audits/reviews, for assigning competent, qualified independent technical auditors/reviewers, and for making sure that appropriate follow-up actions are taken to correct reported deficiencies.

a) Sampling Audits - Sampling audits ensure that the actual field procedures conform to those documented in the Sampling Plans. KCMO WSD may designate an auditor to accompany WSD staff or the Sampling Contractor to the field at any time to perform the sampling audits. The audit may include a check of all field records and a review of all activities to document if procedures were conducted in compliance with the Sampling Plans and QAPP.

b) Laboratory System Audits - Laboratory system audits ensure that the actual laboratory procedures conform to those documented in the Sampling Plans, QAPP, and associated laboratory QA Manual and SOP. KCMO WSD may designate an independent auditor to complete a laboratory audit at any time during the sampling program duration. The audits may include an assessment of all quality system documents, laboratory site visits, and discussions with the laboratory Project Manager, QA/QC Manager, and/or individual staff with regard to methods used, knowledge of quality systems, training, and competency.

4.5 Corrective Action

Corrective actions will be implemented by the sampling and laboratory Project or QA/QC Managers to rectify problems identified during monitoring activities. Possible problems of non-conformance with the Sampling Plan and QAPP requiring corrective action may include, but are not limited to:

• Equipment malfunctions;

• Sampling protocol errors;

• Sampling handling and delivery errors;

• Chain of Custody violations;

• Holding time violations;

• Analytical methodology errors;

• QC data are outside the acceptable range for precision and accuracy;

• Blanks contain target analyses above acceptable levels;

• Undesirable trends are detected in spike recoveries or relative percent difference (RPD) between duplicates;



• Excessive interference is noted; and,

• Deficiencies are detected during field or laboratory audits.

Laboratory project staff and the laboratory QA/QC Manager will be responsible for reporting any suspected non-conformance to the laboratory Project Manager and OCP QA/QC Manager. The OCP and laboratory QA/QC Managers will be responsible for assessing the suspected problems and providing additional training if necessary. The laboratory QA/QC Manager will also be responsible for ensuring that the corrective action for non-conformance takes place by:

• Evaluating all reported incidences of non-conformance;

• Controlling additional work on nonconforming items;

• Determining what corrective action is needed; and

• Implementing and documenting the corrective action.

Full documentation of corrective action procedures will be filed with the OCP Project Manager.



5

5.1

5.2

DATA REVIEW, VERIFICATION, VALIDATION AND USABILITY

The purpose of the Data Review, Validation, Verification, and Usability procedures is to determine if the data meet monitoring objectives. The data generated from monitoring activities will be subjected to a:

• Review of field and laboratory data;

• Evaluation of the data against the method, procedural and/or contractual requirements;

• Validation of data by an objective third party, if necessary; and,

• Assessment of the data for its usability to meet monitoring objectives.

It is the responsibility of all QA/QC Managers and Project Managers to ensure that all four procedures are applied to the collected data.

Data Review

The sampling and laboratory QA/QC Managers will perform data reviews that consist of screening field documentation forms and laboratory data sheets according to screening criteria listed below. If screening criteria are not met, an additional review of available laboratory data (e.g., quality control checks, relevant laboratory bench sheets) may be conducted. Investigation of the issue will be documented and data will be discarded or flagged appropriately, identifying the limitations of the data. Screening criteria may include but are not limited to:

• Temperature readings – check for reasonableness of values;

• pH readings – check for reasonableness of values;

• Dissolved oxygen readings –compare concentrations to percent saturation;

• Conductivity readings – check for reasonableness of values;

• Turbidity readings - check for reasonableness of values;

• Method blanks –values should be less than detection limits;

• Field blanks – values should be less than detection limits; and,

• Review of all analytical results – check for reasonableness of values.

Data Verification

Data verification is the process of evaluating the completeness, correctness, and conformance/compliance of a specific dataset against the method, procedural or contractual requirements.



a) Sampling Activities Data Verification - The sampling Project Manager, with the help of the field staff, will be responsible for ensuring that the samples are collected and handled according to the procedures specified in the sampling plans. Examples of sample activities data verification may include, but are not limited to:

• Verifying the proper calibration and operation of field instruments;

• Confirming that the samples were collected with the proper equipment at the appropriate locations with the appropriate frequency;

• Verifying that the samples were stored in the appropriate containers with the correct preservative;

• Confirming that the samples were stored at the proper temperature during transport from the field to the laboratory;

• Reviewing all field documentation forms, calibration logs, and Chain of Custody forms for accuracy and completeness; and,

• Verifying that QA objectives for accuracy, precision, completeness, and adherence to the required collection techniques are achieved.

b) Laboratory Activities Data Verification - The laboratory Project Manager, with the help of the laboratory staff, will be responsible for verification of laboratory-generated data. Examples of laboratory activities data verification may include, but are not limited to:

• Assessing the data generation procedures for consistency with method requirements as specified in the laboratory’s SOP/SAP, QA Manual, and QA/QC requirements;

• Inspecting the calculations, analytical tests, laboratory bench sheets, and logbooks to verify their accuracy, completeness, and adherence to the specified analytical method protocols;

• Verifying that all instrument systems are working properly and that QA objectives for accuracy, precision, completeness, and adherence to the required detection limits are attained; and

• Examining calibration and QC data on a daily basis.

A summary of reportable QA/QC results and any non-conformance issues will be included in the laboratory deliverable to the OCP Project Manager.

5.3 Data Validation

Data validation is typically performed by someone independent of the project activity and not associated with the organization responsible for producing the dataset. However, the data validator needs to be



familiar with both the data validation requirements and the project objectives. The OCP QA/QC Manager will conduct the data validation. There are four requirements in the data validation process.

The first requirement is to inspect the data, verify and review records to ensure that no oversights were made during that process. A complete set of field and laboratory information for each sample set will be provided to the data validator for this task.

The second requirement is to evaluate the data against the project Data Quality Objectives (DQOs). These DQOs include criteria for accuracy, precision, completeness, representativeness, comparability and compliance with required detection limits. These components are described in Appendix A of this QAPP. If data do not meet one or more of the DQO criteria, the data validation process will include an investigation into causes and an assessment of the impact of the noncompliant data on project objectives. The following must be reviewed as part of the measurement data and analytical data validation activities:

• Field measurement data;

• Field sample collection information;

• Sample custody records;

• Laboratory analytical results;

• Data review information and/or laboratory case narrative; and

• Quality control data.

The data validator will conduct a systematic review of the data for compliance with the established quality control criteria based on duplicate, replicate, spiked, control, and blank data results provided by the laboratory. In addition, quality assurance evaluations of data accuracy, precision, and completeness will be performed on the field measurement data and the laboratory analytical results for each monitored event. The data validation qualifiers listed in Table 5-1 will be used when validating the data.

Table 5-1 Data Validation Qualifiers

Qualifier Definition U The material was analyzed for, but was not detected above the level of the associated

value. The associated value is either the sample quantitation limit or the sample detection limit.

J The associated value is an estimated quantity. R The data are unusable (note: analyte may or may not be present) UJ The material was analyzed for, but was not detected. The associated value is an

estimated level.



If quality control checks or objectives are not attained, an investigation of the non-conformance may be initiated by the data validator with the project team personnel, such as the laboratory Project Manager. The non-conformance will be documented and the affected data set will be flagged appropriately, identifying any limitations.

The third objective of the data validation is to evaluate the data within the context of the project goals. These goals include providing datasets that can be used to develop model inputs, to calibrate and validate the models, and to ensure consistency among different sources of data. Suitable datasets for the modeling portion of this project will be based on the data quality assessment described above as well as an assessment of the spatial and temporal extent of the sample collection. Comparability with other sources of data will be evaluated by comparing and, if necessary, plotting the data with previously collected data to identify outliers or anomalous values.

The fourth objective of the data validations is to communicate the data validation results to the project team in the form of a summary table that lists the validation tasks and the associated results and conclusions. If the validated dataset includes non-compliant data, this data will be addressed in a memo that accompanies the summary table. Data qualifiers assigned to the data during validation will be maintained in the project database to ensure communication of validation results with current and future data users.

5.4 Data Usability

Data are typically usable as long as they have been reviewed, verified and validated. All data quality objectives and criteria control as outlined in Appendix A must be met in order for data to become usable. Once the data has been reviewed, verified, and validated, it will be assembled into a project database by the OCP Project Manager. Other data (such as precipitation, flow data, velocity data, stage data, field notes, and information on any sampling anomalies) must also be included in this database. Any relationships or correlations between the data will be noted.



6

6.1

6.2

DATA MANAGEMENT

The sampling and laboratory Project Managers are responsible for initiating project files and for overseeing maintenance of the files during the course of the project. All project files will be properly identified by project name, project number, file description, and file number. Project files include all appropriate correspondence, memoranda, laboratory bench sheets, laboratory results, audit reports, calculations, technical work products, and other project-related data. In addition, a quality assurance file will be maintained containing all QA/QC related information and documentation. At the conclusion of the project, all relevant information from the project files and computer disks will be archived and retained for a minimum period of three years following archiving.

Field Data and Information Management Documents generated by field activities may include staff notes, field documentation forms, equipment calibration logs, field audit reports, and Chain of Custody forms. Field documentation forms and calibration logs will serve as a daily record of events, observations, calibrations, and measurements taken during field activities. These documents will be stored sequentially in a field log binder and turned over to the OCP Project Manager following each monitored event.

Periodic summary reports will be prepared by the sampling QA/QC Manager to inform the sampling Project Manager of the project status. The reports will include:

• Periodic assessment of measurement data accuracy, precision, and completeness;

• Results of performance audits and/or systems audits;

• Significant QA/QC problems and recommended corrective action; and

• Status of corrective action implementation to any problems previously identified.

Laboratory Data and Information Management

Laboratory data reporting will begin after the laboratory Project Manager has concluded the verification review. The laboratory QA/QC Manager and appropriate staff will prepare and submit analytical, QC, and summary reports to the OCP Project Manager that will include:

• Hard and electronic copy report for all sample results;

• Hard and electronic copy QC summary report for each parameter by batch including the results of any replicates, matrix spikes, matrix spike duplicates, controls, dilution blanks, method blanks, verification tests, etc.;

• Copies of all laboratory bench sheets (if requested);

• Copies of all Chain of Custody forms (if requested);



• Periodic assessment of the data against the Data Quality Objectives and Criteria (prepared by the independent validator);

• Significant QA/QC problems and recommended corrective action; and

• Status of corrective action implementation to any problems previously identified.

6.3 Electronic Data Management

All electronic files will be backed up by the OCP Project Manager on a regular basis. At the conclusion of the project, copies or originals of all relevant information, project files and electronic data will be turned over to the OCP Project Manager. Electronic files will be retained for a minimum period of three years following archiving.

Electronic data also refers to information that is electronically recorded using data loggers (e.g. continuous water quality meters) or cameras. Data logging equipment, if used, will be downloaded as described in the work plans. The data will be backed up immediately after an instrument is downloaded and the download procedure will be logged in field notes as well as on equipment log sheets.



Appendix A Data Quality Objectives and Criteria Control

QAPP_041405_Final.doc FINAL 4/14/2005 A-1


DATA QUALITY OBJECTIVES AND CRITERIA CONTROL

This appendix presents the data quality objectives and criteria control. Data quality will be measured in terms of accuracy, precision, completeness, representativeness, comparability, and the required detection limits for the analytical methods. The criteria for each measure are different depending on the source of the sample (e.g. combined sewer overflow (CSO) vs. stormwater outfall (SWO) vs. receiving water (RW)). These criteria reflect the expected challenges associated with collecting and analyzing representative aliquots of each sample type matrix. Each source and criteria will be discussed in this appendix. Accuracy Accuracy is the measure of the agreement between an observed value and an accepted reference or true value.

Laboratory Accuracy Objectives

Laboratory accuracy will be determined through the analysis of matrix spikes and/or laboratory control samples, as and if required by the analytical methods, to determine percent recoveries (%R). Matrix spikes provide information concerning the effect of the sample matrix on the measurement methodology. Table A-1 provides a summary of the laboratory accuracy objectives. The %R utilizing matrix spikes is calculated as follows:

( )

100 x C

CC = %R

A

US −

Where: CS = measured concentration of spiked sample CU = measured concentration of unspiked sample CA = actual concentration of spike added

The %R utilizing laboratory control samples is calculated as follows:

( )( ) 100 x CC

= %RA

M

Where: CM = measured concentration of control sample CA = actual concentration of control sample

The laboratory will generate dilution and method blank samples, as and if required by the analytical method, for use in assessing contamination resulting from laboratory procedures.



Table A-1 Data Accuracy Objectives

Parameter Estimated by Objective Temperature NA NA pH NA NA Dissolved Oxygen NA NA Conductivity NA NA Turbidity Control 80-120

NH3, NO3+NO2, TKN Control/Matrix Spike 80-120 (Control) 75-125 (RW MS)

60-140 (CSO, SWO MS) CBOD5, CBOD20 Control 80-120

TP, DP Control/Matrix Spike 80-120 (Control) 75-125 (RW MS)

60-140 (CSO, SWO MS) Chlorophyll a Control 80-120 Fecal Coliform (FC) Control Presence/Absence E. Coli Control Presence/Absence TSS, VSS Control 80-120 TDS Control 80-120 COD Control 80-120

Total and Dissolved Metals (Cd, Cu, Cr, Ni, Pb, Zn, Ag)

Control/Matrix Spike 80-120 (Control) 75-125 (RW MS)

60-140 (CSO, SWO MS)

Hardness Control/Matrix Spike 80-120 (Control)

75-125 (RW MS) 60-140 (CSO, SWO MS)

Total Mercury1 Control/Matrix Spike 80-120 (Control) 60-140 (SWO MS)

Oil and Grease1 Control 75-125

Total Phenolics1 Control/Matrix Spike 80-120 (Control) 60-140 (SWO MS)

Semivolatile Base-Neutral Acid Compounds1,2

Control/Matrix Spike See footnote 3

Pesticides (a-BHC, DDD, DDE, DDT, Methoxychlor, Dieldrin) 1,3

Control/Matrix Spike See footnote 4

Notes: 1 These parameters will only be analyzed in the SWO samples, not in the CSO or receiving water samples. 2 Accuracy will be evaluated using a subset of the constituents from this analysis and the following criteria: Acenaphthene: 46-115; 4-

Chloro-3-methylphenol: 23-115; 2-Chlorophenol: 27-115; 2,4-Dinitrotoluene: 24-150; 4-Nitrophenol: 10-115; n-Nitroso-di-n-propylamine: 29-116; Pentachlorophenol: 9-121; Phenol: 12-115; and Pyrene: 26-115. These constituents and criteria are based on the USEPA Contract Lab Program requirements (USEPA, May 1999 SOW).

3 Accuracy will be evaluated using a subset of the constituents from this analysis and the following criteria: 4,4’-DDT: 38-127; and Dieldrin: 52-16. These constituents and criteria are based on the USEPA Contract Lab Program requirements (USEPA, May 1999 SOW).

Control = laboratory control sample NA = not applicable/conducted SWO = storm water outfall CSO = combined sewer overflow RW = receiving water MS = matrix spike



Field Accuracy Objectives

Field accuracy will be assessed through the use of field and equipment blanks. Blanks are used to determine if samples are contaminated during the collection process. Any measured value or signal in a blank sample for an analyte that is absent in the blank solution is typically due to contamination. In order for the accuracy assessment to be relevant, all appropriate protocols concerning sample collection, handling, preservation, and holding times must be followed.

Field blanks will be analyzed to check for procedural contamination during sampling, processing, preservation, transportation, or laboratory handling. Equipment blanks will be analyzed to check for procedural contamination from the collection and processing equipment.

Precision Precision is a measure of the agreement between two or more measurements. Table A-2 provides a summary of the data precision objectives for field and laboratory measurements. Table A-2 applies if the average result of the duplicate/replicate samples is greater than five times the analysis detection limit. If the average result of the duplicate/replicate samples is less than five times the analysis detection limit, the precision test will not be utilized.

Table A-2 Data Precision Objectives

Field Precision – RPD Analytical Precision – RPD Parameter Estimated

By Objective Estimated By Objective

Temperature Readings 10% - NA pH Readings 10% - NA Dissolved Oxygen Readings 10% - NA Conductivity Readings 10% - NA

Turbidity Field Duplicates

30% (RW) 50% (CSO,

SWO)

Lab Replicates

20% (RW) 30% (CSO,

SWO)

NH3, NO3+NO2, TKN Field Duplicates

30% (RW) 40% (CSO,

SWO) MS/MSD

20% (RW) 30% (CSO,

SWO)

CBOD5, CBOD20Field

Duplicates

40% (RW) 50% (CSO,

SWO)

Lab Replicates

20% (RW) 30% (CSO,

SWO)

TP, DP Field Duplicates

30% (RW) 40% (CSO,

SWO) MS/MSD

20% (RW) 30% (CSO,

SWO)

Chlorophyll a Field Duplicates

30% (RW) 40% (CSO,

SWO)

Lab Replicates

20% (RW) 30% (CSO,

SWO)



Table A-2 (continued) Data Precision Objectives

Field Precision – RPD Analytical Precision – RPD Parameter Estimated

By Objective Estimated By Objective

Fecal Coliform (FC) Field Duplicates 50% Lab

Replicates 20%

E. Coli Field Duplicates 50% Lab

Replicates 20%

TSS, VSS Field Duplicates

30% (RW) 40% (CSO,

SWO)

Lab Replicates

20% (RW) 30% (CSO,

SWO)

TDS Field Duplicates

30% (RW) 40% (CSO,

SWO)

Lab Replicates

20% (RW) 30% (CSO,

SWO) Chemical Oxygen Demand (COD)

Field Duplicates 40% (SWO) Lab

Replicates 30% (SWO)

Total and Dissolved Metals (Cd, Cu, Cr, Ni, Pb, Zn, Ag)

Field Duplicates

30% (RW) 40% (CSO,

SWO) MS/MSD

20% (RW) 30% (CSO,

SWO)

Hardness Field Duplicates

30% (RW) 40% (CSO,

SWO) MS/MSD

20% (RW) 30% (CSO,

SWO)

Total Mercury1 Field Duplicates 40% (SWO) MS/MSD 30% (SWO)

Oil and Grease1 Field Duplicates 40% (SWO) Lab

Replicates 30% (SWO)

Total Phenolics1 Field Duplicates 40% (SWO) MS/MSD 30% (SWO)

Semivolatile Base-Neutral Acid Compounds1,2

Field Duplicates 40% (SWO) MS/MSD 20% (SWO)

Pesticides (a-BHC, DDD, DDE, DDT, Methoxychlor, Dieldrin) 1,3

Field Duplicates 40% (SWO) MS/MSD 20% (SWO)

Notes: 1 These parameters will only be analyzed in the SWO samples, not in the CSO or receiving water samples. 2 Precision will be evaluated using a subset of the constituents from this analysis: Acenaphthene; 4-Chloro-3-methylphenol; 2-

Chlorophenol; 2,4-Dinitrotoluene; 4-Nitrophenol; n-Nitroso-di-n-propylamine; Pentachlorophenol; Phenol; and Pyrene. These constituents are adapted from the USEPA Contract Lab Program requirements (USEPA, May 1999 SOW).

3 Precision will be evaluated using a subset of the constituents from this analysis: 4,4’-DDT; and Dieldrin. These constituents are adapted from the USEPA Contract Lab Program requirements (USEPA, May 1999 SOW).

NA = not applicable/conducted SWO = storm water outfall CSO = combined sewer overflow RW = receiving water MS = matrix spike MSD = matrix spike duplicate



Field Precision Objectives

Field precision tests are conducted for grab samples and physical parameter readings. The precision of grab samples is assessed by the comparison of field duplicates. The relative percent difference (RPD) between the analyte levels measured in the field duplicates is calculated as follows:

( 100)5.0×

+

−=

BA

BA

CCCC

RPD

Where: CA = measured concentration of sample CB = measured concentration of duplicate sample

The precision of physical parameter readings may be assessed by the comparison of each instrument’s calibration readings versus the post check readings. The RPD between the readings is calculated as follows:

( 100)5.0×

+

−=

YX

YX

RRRR

RPD

Where: RX = calibration reading RY = post check reading

Laboratory Precision Objectives

The precision of the laboratory analysis is assessed by the comparison of matrix spikes (MS) and matrix spike duplicates (MSD), if required by the analytical method. The RPD between the analyte levels measured in the MS sample and the MSD sample is calculated as follows:

( 100)5.0×

+

−=

MSDMS

MSDMS

CCCC

RPD

Where: CMS = measured concentration of the matrix spike CMSD = measured concentration of the matrix spike duplicate

In situations where spiked samples are not practicable (such as bacteria, CBOD5, and TSS) to assess laboratory precision, a comparison of laboratory replicate analyses may be performed in order to calculate the RPD. In situations where sample volume is limited and precludes the preparation and analysis of MS/MSD or replicates, the RPD between analyte levels measured in the laboratory control sample (LCS) and the laboratory control sample duplicate (LCD) may be used as indication of precision.



Completeness Completeness is a measure of the amount of valid data obtained from the monitoring program compared to the amount of data that were expected. Events that may contribute to reduction in measurement completeness include sample container breakage, inaccessibility to proposed sampling locations, automatic sampler failure, and laboratory equipment failures.

The percent completeness (%C) is determined as follows:

( )( ) 100% ×=

P

V

MM

C

Where: MV = number of valid measurements MP = number of planned measurements

If the completeness objectives are not achieved for any particular category of data, the laboratory Project Manager will provide documentation why the objective was not met and how the lower percentage impacted the overall study objectives. If the objectives of the study are compromised, re-sampling or re-measurement may be necessary.

Field Completeness Objective

Field completeness is determined by the actual number of measurements collected versus the planned number of measurements collected. The details concerning the actual number of field measurements and samples collected are discussed in the sampling plans. The sampling Project Manager will validate the actual number of samples collected. The completeness criterion for all measurements and sample collection is 90 percent, but will be influenced by environmental situations that may alter monitoring schedules.

Laboratory Completeness Objective

Laboratory completeness is determined by the number of valid measurements obtained from all samples submitted for each sampling activity. The laboratory Project Manager assures the validity of the measurements reported and the number of valid measurements. The completeness criterion for all measurements is 95 percent.

Representativeness

Representativeness is the degree to which data accurately and precisely represent a characteristic of a population, parameter variations at a sampling point, a process condition, or an environmental condition. Representative data for dry weather and wet weather conditions are required to support evaluation and modeling efforts.



For sample collection, representativeness will be assured by following the sampling plans and applying proper collection techniques including the proper sample sizes and volumes, and sampling times and locations. Sample volumes depend on the analytical methods and should allow for QC sample analysis and reanalysis, if required. Laboratory representativeness will be ensured by using the appropriate sample preparation techniques, by following appropriate analytical procedures, and by meeting the recommended sample holding times.

Comparability

The objective for data comparability is to generate data for each parameter that are comparable between sampling locations and comparable over time. Data comparability will be promoted by:

• Using standard approved methods where possible;

• Consistently following the sampling methods detailed in the Sampling Plans;

• Consistently following the analytical methods detailed in the laboratory SOPs; and

• Achieving the required detection limits detailed in the QAPP.

All sample collection and analytical methods will be specified, and any deviations from the methods will be documented. All results will be reported in the standard units shown in Table A-3. All field and laboratory calibrations will be performed using standards traceable to National Institute of Science and Technology (NIST) or other U.S. EPA approved sources.

Required Detection Limits

The required detection limits (RDL) and methodology for the study are provided in Table A-3. The RDLs were set to meet project requirements and are based on the WSD experience in having environmental samples analyzed similar to those to be collected. For the analytes specified for this study, all the RDLs are at the usual contract laboratory reporting limits.



Table A-3 Required Detection Limits

Parameter Reference or Methodology Hold Time

Method Detection Limit

(Receiving Water)1

Turbidity EPA 180.1 48 hours 1 NTU NH3 EPA 350.1 28 days 0.05 mg/L NO3+NO2 EPA 353.1 28 days 0.05 mg/L TKN EPA 351.2 28 days 0.1 mg/L CBOD5 EPA 405.1 48 hours 2 mg/L CBOD20 EPA 405.1 48 hours 2 mg/L TP EPA 365.2 28 days 0.05 mg/L

DP EPA 365.2 Filter-24 hours,

Analysis-28 days 0.05 mg/L

Chlorophyll a SM 10200H Filter-24 hours, 21 days 10 ug/L Fecal Coliform (FC) (c) SM 9222 D (a) 6 hours desired,

24 hours accepted Up to 4 dilutions (at most 10 cfu/100 ml)

E. Coli (c) SM 9223 B (a) 6 hours desired, 24 hours accepted

Up to 4 dilutions (at most 10 cfu/100 ml)

Total Suspended Solids (TSS) EPA 160.2 (b) 7 days 1.0 mg/L VSS EPA 160.4 7 days 1.0 mg/L TDS EPA 160.1 7 days 5.0 mg/L Chemical Oxygen Demand (COD) EPA 410.4 28 days 10 mg/L Hardness EPA 130.2 6 months 5 mg/L

Total and Dissolved Cd

EPA 200.7 Filter-24 hours, preserve w/

HNO3, hold 18 hours Analysis-6 months

5 ug/L

Total and Dissolved Cr EPA 200.7 Same as Cd above 5 ug/L Total and Dissolved Cu EPA 200.7 Same as Cd above 5 ug/L Total and Dissolved Ni EPA 200.7 Same as Cd above 5 ug/L Total and Dissolved Pb EPA 200.7 Same as Cd above 5 ug/L Total and Dissolved Zn EPA 200.7 Same as Cd above 5 ug/L Total and Dissolved Ag EPA 200.7 Same as Cd above 5 ug/L Total Mercury EPA 245.2 28 days 0.2 ug/L Total Phenolics EPA 420.2 28 days 50 ug/L Oil and Grease EPA 413.1 28 days 10 mg/L Semivolatile Base, Neutral and Acid Compounds

SW 8270C Extract-7 days, Analysis-40 days

10-50 ug/L

Pesticides (a-BHC, DDD, DDE, DDT, Methoxychlor, Dieldrin)

SW 8081 Extract-7 days, Analysis-40 days

0.05-2 ug/L

Notes: a SM - Standard Methods for the Examination of Water and Wastewater, 20th Edition b U.S. EPA - EPA Methods for Chemical Analysis of Water and Wastes, March 1983 c For samples submitted for bacteriological analysis the maximum allowable holding time will be 24 hours with a goal of 6 hours when practical

(Rayfield, 2003). 1 Additional dilutions may be needed for sources other than receiving water (e.g. for CSO or SWO samples).



Refer to Table A-4 for the specification limits of the field measurement instruments.

Table A-4

Specification Limits of Field Measurement Instruments

Parameter Instrument Range Accuracy Resolution Hydrolab -5 to 50°C ±0.15°C 0.01°C

Temperature YSI -5 to 45°C ±0.15°C 0.01°C Hydrolab 0 to 14 units ±0.2 units 0.01 units

pH YSI 0 to 14 units ±0.2 units 0.01 units Hydrolab 0 to 20 mg/L ±0.2 mg/L 0.01 mg/L

Dissolved Oxygen YSI 0 to 20 mg/L ±0.2 mg/L 0.01 mg/L Hydrolab 0 to 100 mS/cm ±0.5% of range 4 digits

Conductivity YSI 0 to 100 mS/cm ±1% of range 4 digits

Turbidity N/A 0 to 1000 NTU ±2% NTU 4 digits

Notes: 1. Hydrolab, YSI or similar instruments may be used at monitoring stations during the project.
