Document BRv7648MwXN1M7kaEb5yKvaj
EPA Inspection Report - 1 of 81
Region 6 Compliance Assurance and Enforcement Division
INSPECTION REPORT
Inspection Date(s): Media: Regulatory Program(s)
2/18/20 Water NPDES
Company Name: Facility Name: Facility Physical Location:
(city, state, zip code) Mailing address:
(city, state, zip code) County/Parish: Facility Contact:
N/A
Ogle Cattle Co.
312 Cattle Pen Rd,
Bowie, TX 76230
PO Box 1449
Bowie, TX, 76230
Montague
Owner: Chris Ogle
Phone: 940-872-2250
Consultant email: manureisgood@yahoo.com
Facility email: oglecattle@aol.com
FRS Number: Identification/Permit Number: Media Number: NAICS: SIC:
N/A TXG920157 N/A 112111 0211
Personnel participating in inspection:
Collin Martin
6ECD-WA
Juan Ibarra
6ECD-WA
Jack Arias
6ECD-WA
Chelsey Sherwood
6ECD-WA
Inspector Inspector Inspector Inspector
214-665-8380 214-665-8493 214-665-6672 254-233-9945
EPA Lead Inspector Signature/Date
COLLIN MARTIN
{Inspector name}
Digitally signed by COLLIN MARTIN DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=COLLIN MARTIN, 0.9.2342.19200300.100.1.1=68001003655886 Date: 2020.04.03 11:33:44 -05'00'
Date
Supervisor Signature/Date
{Supervisor name}
4/3/2020
Date
6ENFORM-019-R7 (2/15/2017)
1
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Section I - INTRODUCTION
Ogle Cattle Co. Inspection Date 02/18/20
PURPOSE OF THE INSPECTION
EPA Region 6 inspectors Collin Martin, Juan Ibarra, Jack Arias, and Chelsey Sherwood arrived at Ogle Cattle Co. at 9:50 AM on 02/18/20 for an unannounced inspection. The owner of the facility, Larry Ogle, was not available at the time of the inspection, so we dealt directly with his son, Chris Ogle. I presented my credentials to Mr. Ogle as we informed him that this was an EPA inspection to determine the facility's compliance with the Clean Water Act (CWA) National Pollutant Discharge Elimination System (NPDES) Concentrated Animal Feeding Operation (CAFO) regulations and the facility's Texas Commission on Environmental Quality (TCEQ) Permit. This inspection was initiated in response to inspector reconnaissance which documented an overflow of RCS #1 on 2/6/20. The scope of the inspection was a Compliance Evaluation Inspection and included an evaluation of the facility's compliance with their TCEQ CAFO permit. Following the opening conference, we proceeded unaccompanied for the entirety of the inspection.
FACILITY DESCRIPTION
Ogle Cattle Co is a Large CAFO feedlot permitted to confine up to 2999 cattle. At the time of the inspection, according to Chris Ogle, the facility was confining approximately 1200 head of beef cattle. The cattle were housed in approximately 25 acres of open lots. The facility had one (1) Retention Control Structure (RCS) which was designed to receive process wastewater from the facility's production area. Wastewater pumped out of this RCS was used to irrigate three (3) Land Management Units (LMUs). These three (3) LMUs total 393 acres and are irrigated via a reel gun and risers. Commodities were stored in a barn.
Section II - OBSERVATIONS
Wastewater & Solids Conveyance On the day of the inspection, we observed that the northeast corner of the open lot nearest RCS #1 was inadequately graded [Area Of Concern (AOC) 1]. This approximately 0.7-acre area was sloped in such a way that any process wastewater emanating from it would not be conveyed to RCS #1. Instead, this area appeared to slope toward the low area between RCS #1 and HWY 287 which had a direct connection to Brier Creek. Additionally, we observed a large pile of manure being stored in an area just north of RCS #1 (Photo #14). This area was graded such that it was not contained within the watershed of RCS #1 [AOC 2]. We also observed tall grass growing on top of this pile which was evidence of storage for greater than the 30 days of temporary storage allowed per TXG920157.
Retention Control Structures On the day of the inspection we observed a discharge emanating from the northwestern corner of RCS #1 [AOC 3] (Photo #6). We followed the flowpath of this discharge until it reached Brier Creek (Photos #11-12). We collected two samples of this discharge which are explained in Discharge Sampling Results
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Ogle Cattle Co. Inspection Date 02/18/20
below. Additionally, we observed that the pole marker was totally submerged at the time of the inspection [AOC 4] and that woody vegetation had taken root within the northern embankment of RCS #1 [AOC 5] (Photo #18).
Silage and Commodities Storage On the day of our inspection I observed the facility's commodity storage to be adequate. Hay and commodities were being stored covered in a barn.
Records Review On 3/2/2020, the facility's consultant emailed us digital copies of the facility's records. I reviewed these records and found them to be accurate and up to date. However, records must be made readily available during the course of an inspection. Weekly lagoon level reading records showed that RCS #1 was consistently above its pump-out mark beginning December 21st, 2019 (one (1) foot above) until February 18th, 2020 (five (5) feet above) [AOC 6]. According to the facility irrigation records, there was no attempt made to land-apply effluent to an LMU between 10/25/2019 and 2/21/2020 [AOC 7].
Discharge Sampling Results Water Samples were taken at the point of discharge from RCS #1 and just upstream of the point in which wastewater entered Brier Creek. All samples were analyzed for the following parameters: E. Coli, Total Coliforms, Total Kjeldahl Nitrogen (TKN), Nitrate/Nitrite as N, Ammonia as N, and Total Phosphorus. These samples contained high nutrient loading and high fecal content. The lab's analytical results are contained within Appendix 2 and summarized in the table below.
Lagoon Discharge Brier Creek
Bacteria Blank
E. Coli,
>24196 MPN/100mL >24196 MPN/100mL <1 MPN/100mL
Total Coliforms
>24196 MPN/100mL >24196 MPN/100mL <1 MPN/100mL
Total Kjeldahl Nitroge n (TKN), 91.0 mg/L 58.5 mg/L NA
Nitrate/Nitrite as N
ND mg/L ND mg/L NA
Ammonia as N
45.2 mg/L 27.1 mg/L NA
Total Phosphorus
27.8 mg/L 20.7 mg/L NA
Section III - AREAS OF CONCERN
The following Areas of Concern were conveyed to facility's consultant, Noel Courts during the closing conference:
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Ogle Cattle Co. Inspection Date 02/18/20 1. An area approximately 0.7 acres located in the northeast corner of the open lot nearest RCS #1 was not graded in a way that allowed for proper drainage to RCS #1 as required by TXG920157 Part III.A.6(c)(2). 2. Piles of manure were being stored uncovered adjacent to RCS #1. Per TXG920157 Part III.A.9(b) manure or sludge stored for more than 30 days must be stored within the drainage area of an RCS or stored in a manner (i.e. storage shed, bermed area, tarp covered area, etc.) that otherwise prevents contaminated storm water runoff from the storage area.
3. Process wastewater was discharging from the northwestern corner of RCS #1. Per TXG920157,
the facility shall not discharge unless at least one of the criteria in Part III.A.5(3)(ii) is met. 4. The permanent pond marker in RCS #1 was completely submerged. Per TXG920157 Part
III.A.10(c), permanent pond markers must be visible from the top of the embankment. 5. Small woody vegetation had taken root within the embankment of RCS #1. This vegetation will
need to be removed to prevent the plant's root zone from intruding into the RCS liner per TXG920157 Part III.A.10(f)(3). 6. Weekly lagoon level readings showed that RCS #1 was above the pump-out mark for 60 consecutive days from 12/21/19 through 2/21/20. Per TXG920157 Part III.A.10(a), the normal operating wastewater level in the RCS shall be maintained in accordance with the design of the RCS and the permittee shall ensure that the required capacity in the RCS is available to contain rainfall and rainfall runoff from the design rainfall event. 7. No attempt was made to dewater in the event of imminent overflow as required by TXG920157 Part III.A.10(b)
Section IV - LIST OF APPENDICES
Appendix 1 - Photo Log - 18 photos taken 2/18/20 (Photos #1-18), 13 photos taken 2/6/20 (Photos #1930) and 1 aerial image of significant photo locations
Appendix 2 - Pace Lab's analytical report of samples taken 2/18/20
Appendix 3 - Quality Assurance Project Plan
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Ogle Cattle Co. Inspection Date 2/18/20
Appendix 1 Photograph Log
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 1
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: 1.jpg Date of Photo: 2/18/2020 Photographer: Chelsey Sherwood Description: This photo was taken from the northern berm of RCS #1 facing west. Note the impression evident in the berm. The facility's consultant informed us that they believed them to be wild hog walkline tracks.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 2
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: 2.jpg Date of Photo: 2/18/2020 Photographer: Chelsey Sherwood Description: This photo was taken from base of the northern berm of RCS #1 facing south. Note the impression evident in the berm. The facility's consultant informed us that they believed them to be wild hog walk-line tracks.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 3
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: 3.jpg Date of Photo: 2/18/2020 Photographer: Chelsey Sherwood Description: This photo was taken from the top of the northern berm of RCS #1 facing east. Note the impression which appears to run from the interior of RCS #1 directly to Brier Creek. The facility's consultant informed us that they believed them to be wild hog walk-line tracks.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 4
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: 4.jpg Date of Photo: 2/18/2020 Photographer: Chelsey Sherwood Description: This photo was taken at the point where the impression meets the RCS #1 discharge conveyance.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 5
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: 5.jpg Date of Photo: 2/18/2020 Photographer: Chelsey Sherwood Description: This photo was taken facing southeast toward the point at which the discharge from RCS #1 meets Brier Creek.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 6
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: 6 sample one.jpg Date of Photo: 2/18/2020 Photographer: Chelsey Sherwood Description: This photo was taken facing west across the discharge as it exited RCS #1 The sample containers in the photo were sitting just to the right of where they were collected.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 7
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: 7 dup.jpg Date of Photo: 2/18/2020 Photographer: Chelsey Sherwood Description: This photo was taken facing east across the flowpath of the discharge.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 8
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: 7.jpg Date of Photo: 2/18/2020 Time of Photo: 9:20 AM Photographer: Chelsey Sherwood Description: This photo was taken facing southeast across the flowpath of the discharge from RCS #1.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 9
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: 9.jpg Date of Photo: 2/18/2020 Photographer: Chelsey Sherwood Description: This photo was taken facing southeast across the flowpath of the discharge from RCS #1.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 10
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: 10.jpg Date of Photo: 2/18/2020 Photographer: Chelsey Sherwood Description: This photo was taken facing the discharge from RCS #1. Note the ripples in the discharge which were evidence of active flow.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 11
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: 11 sample two.jpg Date of Photo: 2/18/2020 Time of Photo: 9:21 AM Photographer: Chelsey Sherwood Description: This photo was taken facing southeast towards Brier Creek at the second sampling location. The sample containers in the photo were sitting just to the right of where they were collected.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 12
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: 12.jpg Date of Photo: 2/18/2020 Time of Photo: 9:21 AM Photographer: Chelsey Sherwood Description: This photo was taken facing south across Brier Creek.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 13
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: 13.jpg Date of Photo: 2/18/2020 Photographer: Chelsey Sherwood Description: This photo was taken facing north towards Brier Creek as it passed under Hwy 287.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 14
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: 14.jpg Date of Photo: 2/18/2020 Photographer: Chelsey Sherwood Description: This photo was taken facing west towards the manure pile that was stored outside of the watershed of RCS #1.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 15
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: 15.jpg Date of Photo: 2/18/2020 Photographer: Chelsey Sherwood Description: This photo was taken facing northwest. Note the lack of a berm below the gate. Any process wastewater which emanated from this 0.7-acre area would have flowed toward this low point and towards Brier Creek.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 16
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: 18.jpg Date of Photo: 2/18/2020 Photographer: Chelsey Sherwood Description: This photo was taken facing southwest toward the stomped-out pasture feeding area. Stomped out areas surrounding feed and watering areas are permitted, but as a best management practice, feed and water troughs should be rotated to minimize the size of the affected area.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 17
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: 22.jpg Date of Photo: 2/18/2020 Photographer: Chelsey Sherwood Description: This photo was taken facing northwest toward the southernmost open lot on the west side of the production area. The very low berm present at this corner would likely be inadequate to channel and contain the 25 yr/24 hr rain event toward the RCS. Because of this, runoff from this area would likely go to the bar ditch and thence Brier Creek.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 18
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: lagoon.jpg Date of Photo: 2/18/2020 Photographer: Chelsey Sherwood Description: This photo was taken facing south across RCS #1. Note the woody vegetation rooted within the berm.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 19
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: Pic1-64783DC4-46AA-4FDA-AADF-F7A83F262A96.jpeg Date of Photo: 2/6/2020 Photographer: Carl Wills Description: Photo taken of the discharge from the HWY 287 access road.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 20
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: Pic2_B5B5654B-23A3-4C33-AEA8-FF981BF50B6D.jpeg Date of Photo: 2/6/2020 Photographer: Carl Wills Description: Photo taken of the discharge from the HWY 287 access road.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 21
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: Pic3_1B42063B-AEA3-45F1-B587-4E23C2C50E5B.jpeg Date of Photo: 2/6/2020 Photographer: Carl Wills Description: Photo taken of the discharge from the HWY 287 access road.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 22
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: Pic4_2EAD272B-CF33-41A0-BC85-C47A0173A302.jpeg Date of Photo: 2/6/2020 Photographer: Carl Wills Description: Photo taken of the discharge from the HWY 287 access road.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 23
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: Pic5_F8CF5E93-019F-456A-9F4F-FD33136F91DE.jpeg Date of Photo: 2/6/2020 Photographer: Carl Wills Description: Photo taken of the discharge from the HWY 287 access road.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 24
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: Pic6_104B1882-AC25-4E98-8771-58842B3A4ED2.jpeg Date of Photo: 2/6/2020 Photographer: Carl Wills Description: Photo taken of the discharge from the HWY 287 access road.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 25
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: Pic7_9B670862-5D32-4B00-B1F9-F8AB0ED6FBB4.jpeg Date of Photo: 2/6/2020 Photographer: Carl Wills Description: Photo taken of the discharge from the HWY 287 access road.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 26
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: Pic8_4E26F438-65A5-49D7-A8C8-38EC90C0CEEA.jpeg Date of Photo: 2/6/2020 Photographer: Carl Wills Description: Photo taken of the discharge from the HWY 287 access road.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 27
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: Pic9_8018C242-63F5-4883-89BF-326A4CD0406C.jpeg Date of Photo: 2/6/2020 Photographer: Carl Wills Description: Photo taken of the discharge from the HWY 287 access road.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 28
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: Pic10_71D459BF-A6DF-459B-8306-F56E32D306F8.jpeg Date of Photo: 2/6/2020 Photographer: Carl Wills Description: Photo taken of the discharge by the property's northern fence line.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 29
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: Pic12_D00F49F5-1F45-4806-B570-B895E2D8EBC0.jpeg Date of Photo: 2/6/2020 Photographer: Carl Wills Description: Photo taken of the discharge by the property's northern fence line.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 30
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
Photo File Name: Pic13_1BDDECD3-7E55-461B-B32F-F6E7FBBB244C.jpeg Date of Photo: 2/6/2020 Photographer: Carl Wills Description: Photo taken of the discharge by the property's northern fence line.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 31
Location: Ogle Cattle Co. 312 Cattle Pen Rd.
City: Bowie
County/Parish: Montague
State: Texas
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Ogle Cattle Co. Inspection Date 2/18/20
Appendix 2 Sample Results
#=CL#
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LIMS USE: FR - COLLIN MARTIN LIMS OBJECT ID: 75125858
February 27, 2020
Pace Analytical Services, LLC 400 West Bethany Drive - Suite 190
Allen, TX 75013 (972)727-1123
Collin Martin EPA Region 6 1445 Ross Avenue, Suite 1200 Dallas, TX 75202
RE: Project: Ogle Cattle Co Pace Project No.: 75125858
Dear Collin Martin: Enclosed are the analytical results for sample(s) received by the laboratory on February 18, 2020. The results relate only to the samples included in this report. Results reported herein conform to the most current, applicable TNI/NELAC standards and the laboratory's Quality Assurance Manual, where applicable, unless otherwise noted in the body of the report.
If you have any questions concerning this report, please feel free to contact me.
Sincerely,
Melissa McCullough melissa.mccullough@pacelabs.com (972)727-1123 Project Manager
Enclosures
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, LLC.
Page 1 of 18
#=CP#
EPA Inspection Report - 39 of 81
Pace Analytical Services, LLC 400 West Bethany Drive - Suite 190
Allen, TX 75013 (972)727-1123
Project: Pace Project No.:
Ogle Cattle Co 75125858
Pace Analytical Services Kansas 9608 Loiret Boulevard, Lenexa, KS 66219 Missouri Inorganic Drinking Water Certification #: 10090 Arkansas Drinking Water Arkansas Certification #: 19-016-0 Arkansas Drinking Water Illinois Certification #: 004455 Iowa Certification #: 118 Kansas/NELAP Certification #: E-10116 Louisiana Certification #: 03055
Pace Analytical Services Dallas 400 West Bethany Dr Suite 190, Allen, TX 75013 EPA# TX00074 Texas T104704232-19-29 Florida Certification #: E871118 Texas Certification #: T104704232-18-26
Pace Analytical Services Fort Worth 2657 Gravel Dr, Fort Worth, Texas 76118 Texas Certification #: T104704232-18-24
CERTIFICATIONS
Nevada Certification #: KS000212020-2 Oklahoma Certification #: 9205/9935 Florida: Cert E871149 SEKS WET Texas Certification #: T104704407-19-12 Utah Certification #: KS000212018-8 Illinois Certification #: 004592 Kansas Field Laboratory Accreditation: # E-92587 Missouri SEKS Micro Certification: 10070
Kansas Certification #: E-10388 Arkansas Certification #: 88-0647 Oklahoma Certification #: 8727 Louisiana Certification #: 30686 Iowa Certification #: 408
Texas T104704232-19-29 EPA# TX00074
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, LLC.
Page 2 of 18
#=SS#
EPA Inspection Report - 40 of 81
Project: Pace Project No.:
Ogle Cattle Co 75125858
Lab ID
Sample ID
75125858001 75125858002 75125858003 75125858004 75125858005
Lagoon Disch 6-301803 Lagoon Disch 6-410913 Lagoon Disch 6-301804 Brier Creek 6-301802 Brier Creek 6-410914
SAMPLE SUMMARY
Pace Analytical Services, LLC 400 West Bethany Drive - Suite 190
Allen, TX 75013 (972)727-1123
Matrix
Water Water Water Water Water
Date Collected
02/18/20 10:29 02/18/20 12:14 02/18/20 10:29 02/18/20 10:47 02/18/20 10:47
Date Received
02/18/20 15:10 02/18/20 15:10 02/18/20 15:10 02/18/20 15:10 02/18/20 15:10
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, LLC.
Page 3 of 18
#=SA#
EPA Inspection Report - 41 of 81
Project: Pace Project No.:
Ogle Cattle Co 75125858
Lab ID
75125858001 75125858002 75125858003
Sample ID
Lagoon Disch 6-301803 Lagoon Disch 6-410913 Lagoon Disch 6-301804
75125858004 75125858005
Brier Creek 6-301802 Brier Creek 6-410914
SAMPLE ANALYTE COUNT
Method SM 9223, Colilert SM 9223, Colilert
EPA 351.2 EPA 353.2 SM 4500-NH3 H SM 4500-P E SM 9223, Colilert EPA 351.2 EPA 353.2 SM 4500-NH3 H SM 4500-P E
Pace Analytical Services, LLC 400 West Bethany Drive - Suite 190
Allen, TX 75013 (972)727-1123
Analysts
DHH DHH AJS LVH LVH RMB DHH AJS LVH LVH RMB
Analytes Reported
Laboratory
2 PASI-FTW
2 PASI-FTW
1
PASI-K
1 PASI-D
1 PASI-D
1 PASI-D
2 PASI-FTW
1
PASI-K
1 PASI-D
1 PASI-D
1 PASI-D
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, LLC.
Page 4 of 18
#=AR#
EPA Inspection Report - 42 of 81
Pace Analytical Services, LLC 400 West Bethany Drive - Suite 190
Allen, TX 75013 (972)727-1123
Project: Pace Project No.:
Ogle Cattle Co 75125858
Sample: Lagoon Disch 6-301803
Parameters
MBIO Total Ecoli
Total Coliforms Escherichia coli (E.coli)
ANALYTICAL RESULTS
Lab ID: 75125858001
Results
Units
Collected: 02/18/20 10:29 Received: 02/18/20 15:10 Matrix: Water
Report Limit DF
Prepared
Analyzed
CAS No.
Analytical Method: SM 9223, Colilert Preparation Method: SM 9223, Colilert
>24196 >24196
MPN/100mL MPN/100mL
10.0 10 02/18/20 16:55 02/19/20 17:06 10.0 10 02/18/20 16:55 02/19/20 17:06
Qual
Date: 02/27/2020 04:37 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, LLC.
Page 5 of 18
#=AR#
EPA Inspection Report - 43 of 81
Pace Analytical Services, LLC 400 West Bethany Drive - Suite 190
Allen, TX 75013 (972)727-1123
Project: Pace Project No.:
Ogle Cattle Co 75125858
Sample: Lagoon Disch 6-410913
Parameters
MBIO Total Ecoli
Total Coliforms Escherichia coli (E.coli)
ANALYTICAL RESULTS
Lab ID: 75125858002
Results
Units
Collected: 02/18/20 12:14 Received: 02/18/20 15:10 Matrix: Water
Report Limit DF
Prepared
Analyzed
CAS No.
Analytical Method: SM 9223, Colilert Preparation Method: SM 9223, Colilert
<1 MPN/100mL <1 MPN/100mL
1.0 1 02/18/20 16:55 02/19/20 17:07 1.0 1 02/18/20 16:55 02/19/20 17:07
Qual
Date: 02/27/2020 04:37 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, LLC.
Page 6 of 18
#=AR#
EPA Inspection Report - 44 of 81
Pace Analytical Services, LLC 400 West Bethany Drive - Suite 190
Allen, TX 75013 (972)727-1123
Project: Pace Project No.:
Ogle Cattle Co 75125858
Sample: Lagoon Disch 6-301804
Parameters
351.2 Total Kjeldahl Nitrogen Nitrogen, Kjeldahl, Total 353.2 Nitrogen, NO2/NO3 pres Nitrogen, NO2 plus NO3 4500 Ammonia Water Nitrogen, Ammonia SM4500P-E, Total Phosphorus Phosphorus
ANALYTICAL RESULTS
Lab ID: 75125858003
Results
Units
Collected: 02/18/20 10:29 Received: 02/18/20 15:10 Matrix: Water
Report Limit DF
Prepared
Analyzed
CAS No.
Analytical Method: EPA 351.2 Preparation Method: EPA 351.2
91.0
mg/L
5.0 5 02/21/20 08:57 02/24/20 13:45 7727-37-9
Analytical Method: EPA 353.2
ND
mg/L
0.050 1
02/25/20 11:58
Analytical Method: SM 4500-NH3 H
45.2
mg/L
0.50 5
02/21/20 14:52 7664-41-7
Analytical Method: SM 4500-P E Preparation Method: SM4500-P B
27.8
mg/L
2.5 50 02/20/20 14:29 02/20/20 17:03 7723-14-0
Qual
Date: 02/27/2020 04:37 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, LLC.
Page 7 of 18
#=AR#
EPA Inspection Report - 45 of 81
Pace Analytical Services, LLC 400 West Bethany Drive - Suite 190
Allen, TX 75013 (972)727-1123
Project: Pace Project No.:
Ogle Cattle Co 75125858
Sample: Brier Creek 6-301802
Parameters
MBIO Total Ecoli
Total Coliforms Escherichia coli (E.coli)
ANALYTICAL RESULTS
Lab ID: 75125858004
Results
Units
Collected: 02/18/20 10:47 Received: 02/18/20 15:10 Matrix: Water
Report Limit DF
Prepared
Analyzed
CAS No.
Analytical Method: SM 9223, Colilert Preparation Method: SM 9223, Colilert
>24196 >24196
MPN/100mL MPN/100mL
10.0 10 02/18/20 16:55 02/19/20 17:06 10.0 10 02/18/20 16:55 02/19/20 17:06
Qual
Date: 02/27/2020 04:37 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, LLC.
Page 8 of 18
#=AR#
EPA Inspection Report - 46 of 81
Pace Analytical Services, LLC 400 West Bethany Drive - Suite 190
Allen, TX 75013 (972)727-1123
Project: Pace Project No.:
Ogle Cattle Co 75125858
Sample: Brier Creek 6-410914
Parameters
351.2 Total Kjeldahl Nitrogen Nitrogen, Kjeldahl, Total 353.2 Nitrogen, NO2/NO3 pres Nitrogen, NO2 plus NO3 4500 Ammonia Water Nitrogen, Ammonia SM4500P-E, Total Phosphorus Phosphorus
ANALYTICAL RESULTS
Lab ID: 75125858005
Results
Units
Collected: 02/18/20 10:47 Received: 02/18/20 15:10 Matrix: Water
Report Limit DF
Prepared
Analyzed
CAS No.
Analytical Method: EPA 351.2 Preparation Method: EPA 351.2
58.5
mg/L
2.5 5 02/21/20 08:57 02/24/20 13:46 7727-37-9
Analytical Method: EPA 353.2
ND
mg/L
0.050 1
02/25/20 12:00
Analytical Method: SM 4500-NH3 H
27.1
mg/L
0.50 5
02/21/20 14:53 7664-41-7
Analytical Method: SM 4500-P E Preparation Method: SM4500-P B
20.7
mg/L
1.2 25 02/20/20 14:29 02/20/20 16:51 7723-14-0
Qual
Date: 02/27/2020 04:37 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, LLC.
Page 9 of 18
#=QC#
EPA Inspection Report - 47 of 81
Pace Analytical Services, LLC 400 West Bethany Drive - Suite 190
Allen, TX 75013 (972)727-1123
QUALITY CONTROL DATA
Project: Pace Project No.:
Ogle Cattle Co 75125858
QC Batch:
135459
Analysis Method:
QC Batch Method: SM 9223, Colilert
Analysis Description:
Associated Lab Samples: 75125858001, 75125858002, 75125858004
SM 9223, Colilert 9223B MBIO Total Ecoli
METHOD BLANK: 616671
Matrix: Water
Associated Lab Samples: 75125858001, 75125858002, 75125858004
Parameter
Units
Blank Result
Reporting Limit
Escherichia coli (E.coli) Total Coliforms
MPN/100mL MPN/100mL
<1
1.0
<1
1.0
Analyzed
02/19/20 17:06 02/19/20 17:06
Qualifiers
SAMPLE DUPLICATE: 616672
Parameter Escherichia coli (E.coli) Total Coliforms
Units
MPN/100mL MPN/100mL
75125847001 Result
<1 93.3
Dup Result
<1 83.9
RPD
Max RPD
Qualifiers
Results presented on this page are in the units indicated by the "Units" column except where an alternate unit is presented to the right of the result.
Date: 02/27/2020 04:37 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, LLC.
Page 10 of 18
#=QC#
EPA Inspection Report - 48 of 81
Pace Analytical Services, LLC 400 West Bethany Drive - Suite 190
Allen, TX 75013 (972)727-1123
QUALITY CONTROL DATA
Project: Pace Project No.:
Ogle Cattle Co 75125858
QC Batch:
639572
QC Batch Method: EPA 351.2
Associated Lab Samples: 75125858003, 75125858005
METHOD BLANK: 2600347 Associated Lab Samples: 75125858003, 75125858005
Parameter Nitrogen, Kjeldahl, Total
Units mg/L
Analysis Method: Analysis Description:
EPA 351.2 351.2 TKN
Matrix: Water
Blank Result
ND
Reporting Limit
0.50
Analyzed 02/24/20 11:59
Qualifiers
LABORATORY CONTROL SAMPLE: 2600348
Parameter Nitrogen, Kjeldahl, Total
Units mg/L
Spike Conc.
5
LCS Result
5.2
LCS % Rec
103
% Rec Limits
90-110
Qualifiers
MATRIX SPIKE SAMPLE:
Parameter Nitrogen, Kjeldahl, Total
2600349
Units mg/L
60328827006 Result
0.62
Spike Conc.
5
MS Result
6.0
MS % Rec
107
% Rec Limits
90-110
Qualifiers
MATRIX SPIKE SAMPLE:
Parameter Nitrogen, Kjeldahl, Total
2600351
Units mg/L
60328859001 Result
45.1
Spike Conc.
10
MS Result
61.7
MS % Rec
166
% Rec Limits
Qualifiers
90-110 M1
SAMPLE DUPLICATE: 2600350
Parameter Nitrogen, Kjeldahl, Total
Units mg/L
60328830002 Result
10.4
Dup Result
10.4
RPD 0
Max RPD
10
Qualifiers
Results presented on this page are in the units indicated by the "Units" column except where an alternate unit is presented to the right of the result.
Date: 02/27/2020 04:37 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, LLC.
Page 11 of 18
#=QC#
EPA Inspection Report - 49 of 81
Pace Analytical Services, LLC 400 West Bethany Drive - Suite 190
Allen, TX 75013 (972)727-1123
QUALITY CONTROL DATA
Project: Pace Project No.:
Ogle Cattle Co 75125858
QC Batch:
135882
QC Batch Method: EPA 353.2
Associated Lab Samples: 75125858003, 75125858005
METHOD BLANK: 618928 Associated Lab Samples: 75125858003, 75125858005
Parameter Nitrogen, NO2 plus NO3
Units mg/L
Analysis Method: Analysis Description:
EPA 353.2 353.2 Nitrate + Nitrite, pres.
Matrix: Water
Blank Result
ND
Reporting Limit
0.050
Analyzed 02/25/20 11:52
Qualifiers
LABORATORY CONTROL SAMPLE: 618929
Parameter Nitrogen, NO2 plus NO3
Units mg/L
Spike Conc.
2.5
LCS Result
2.5
LCS % Rec
101
% Rec Limits
90-110
Qualifiers
MATRIX SPIKE & MATRIX SPIKE DUPLICATE: 618930
MS
75125630002 Spike
Parameter
Units
Result Conc.
Nitrogen, NO2 plus NO3
mg/L
0.052
2.5
MSD Spike Conc.
2.5
618931
MS Result
2.4
MSD Result
2.5
MS % Rec
93
MSD % Rec
97
% Rec Limits
Max RPD RPD
90-110
4 20
Qual
MATRIX SPIKE & MATRIX SPIKE DUPLICATE: 618932
MS
75126083001 Spike
Parameter
Units
Result Conc.
Nitrogen, NO2 plus NO3
mg/L
0.14
2.5
MSD Spike Conc.
2.5
618933
MS Result
2.6
MSD Result
2.6
MS % Rec
99
MSD % Rec
99
% Rec Limits
Max RPD RPD
90-110
0 20
Qual
Results presented on this page are in the units indicated by the "Units" column except where an alternate unit is presented to the right of the result.
Date: 02/27/2020 04:37 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, LLC.
Page 12 of 18
#=QC#
EPA Inspection Report - 50 of 81
Pace Analytical Services, LLC 400 West Bethany Drive - Suite 190
Allen, TX 75013 (972)727-1123
QUALITY CONTROL DATA
Project: Pace Project No.:
Ogle Cattle Co 75125858
QC Batch:
135701
QC Batch Method: SM 4500-NH3 H
Associated Lab Samples: 75125858003, 75125858005
METHOD BLANK: 617923 Associated Lab Samples: 75125858003, 75125858005
Parameter Nitrogen, Ammonia
Units mg/L
Analysis Method: Analysis Description:
SM 4500-NH3 H 4500 Ammonia
Matrix: Water
Blank Result
ND
Reporting Limit
0.10
Analyzed 02/21/20 12:40
Qualifiers
LABORATORY CONTROL SAMPLE: 617924
Parameter Nitrogen, Ammonia
Units mg/L
Spike Conc.
5
LCS Result
5.0
LCS % Rec
101
% Rec Limits
80-120
Qualifiers
MATRIX SPIKE & MATRIX SPIKE DUPLICATE: 617925
MS
75125634001 Spike
Parameter
Units
Result Conc.
Nitrogen, Ammonia
mg/L
ND
5
MSD Spike Conc.
5
617926
MS Result
4.9
MSD Result
4.9
MS % Rec
98
MSD % Rec
97
% Rec Limits
Max RPD RPD
80-120
1 20
Qual
MATRIX SPIKE & MATRIX SPIKE DUPLICATE: 617927
MS
75125672001 Spike
Parameter
Units
Result Conc.
Nitrogen, Ammonia
mg/L
ND
5
MSD Spike Conc.
5
617928
MS Result
5.0
MSD Result
4.9
MS % Rec
98
MSD % Rec
97
% Rec Limits
Max RPD RPD
80-120
0 20
Qual
Results presented on this page are in the units indicated by the "Units" column except where an alternate unit is presented to the right of the result.
Date: 02/27/2020 04:37 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, LLC.
Page 13 of 18
#=QC#
EPA Inspection Report - 51 of 81
Pace Analytical Services, LLC 400 West Bethany Drive - Suite 190
Allen, TX 75013 (972)727-1123
QUALITY CONTROL DATA
Project: Pace Project No.:
Ogle Cattle Co 75125858
QC Batch:
135602
QC Batch Method: SM4500-P B
Associated Lab Samples: 75125858003, 75125858005
METHOD BLANK: 617432 Associated Lab Samples: 75125858003, 75125858005
Parameter Phosphorus
Units mg/L
Analysis Method: Analysis Description:
SM 4500-P E SM4500P-E, Total Phosphorus
Matrix: Water
Blank Result
ND
Reporting Limit
0.050
Analyzed 02/20/20 16:15
Qualifiers
LABORATORY CONTROL SAMPLE: 617433
Parameter Phosphorus
Units mg/L
Spike Conc.
0.5
LCS Result
0.51
LCS % Rec
102
% Rec Limits
80-120
Qualifiers
MATRIX SPIKE & MATRIX SPIKE DUPLICATE: 617488
MS
20142302002 Spike
Parameter
Units
Result Conc.
Phosphorus
mg/L
0.78
0.5
MSD Spike Conc.
0.5
617489
MS Result
1.2
MSD Result
1.3
MS % Rec
91
MSD % Rec
96
% Rec Limits
Max RPD RPD
80-120
2 20
Qual
MATRIX SPIKE & MATRIX SPIKE DUPLICATE: 617490
MS
20142299002 Spike
Parameter
Units
Result Conc.
Phosphorus
mg/L
0.31
0.5
MSD Spike Conc.
0.5
617491
MS Result
0.78
MSD Result
0.78
MS % Rec
94
MSD % Rec
95
% Rec Limits
Max RPD RPD
80-120
1 20
Qual
Results presented on this page are in the units indicated by the "Units" column except where an alternate unit is presented to the right of the result.
Date: 02/27/2020 04:37 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, LLC.
Page 14 of 18
#=QL#
EPA Inspection Report - 52 of 81
Pace Analytical Services, LLC 400 West Bethany Drive - Suite 190
Allen, TX 75013 (972)727-1123
QUALIFIERS
Project: Pace Project No.:
Ogle Cattle Co 75125858
DEFINITIONS
DF - Dilution Factor, if reported, represents the factor applied to the reported data due to dilution of the sample aliquot. ND - Not Detected at or above adjusted reporting limit. TNTC - Too Numerous To Count J - Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit. MDL - Adjusted Method Detection Limit. PQL - Practical Quantitation Limit. RL - Reporting Limit - The lowest concentration value that meets project requirements for quantitative data with known precision and bias for a specific analyte in a specific matrix. S - Surrogate 1,2-Diphenylhydrazine decomposes to and cannot be separated from Azobenzene using Method 8270. The result for each analyte is a combined concentration. Consistent with EPA guidelines, unrounded data are displayed and have been used to calculate % recovery and RPD values. LCS(D) - Laboratory Control Sample (Duplicate) MS(D) - Matrix Spike (Duplicate) DUP - Sample Duplicate RPD - Relative Percent Difference NC - Not Calculable. SG - Silica Gel - Clean-Up U - Indicates the compound was analyzed for, but not detected. N-Nitrosodiphenylamine decomposes and cannot be separated from Diphenylamine using Method 8270. The result reported for each analyte is a combined concentration. Pace Analytical is TNI accredited. Contact your Pace PM for the current list of accredited analytes. TNI - The Nelac Institute
LABORATORIES
PASI-D PASI-FTW PASI-K
Pace Analytical Services - Dallas Pace Analytical Services - Fort Worth Pace Analytical Services - Kansas City
ANALYTE QUALIFIERS
M1
Matrix spike recovery exceeded QC limits. Batch accepted based on laboratory control sample (LCS) recovery.
Date: 02/27/2020 04:37 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, LLC.
Page 15 of 18
#=CR#
EPA Inspection Report - 53 of 81
Pace Analytical Services, LLC 400 West Bethany Drive - Suite 190
Allen, TX 75013 (972)727-1123
Project: Pace Project No.:
Ogle Cattle Co 75125858
QUALITY CONTROL DATA CROSS REFERENCE TABLE
Lab ID
75125858001 75125858002 75125858004
75125858003 75125858005
75125858003 75125858005
75125858003 75125858005
75125858003 75125858005
Sample ID
Lagoon Disch 6-301803 Lagoon Disch 6-410913 Brier Creek 6-301802
Lagoon Disch 6-301804 Brier Creek 6-410914
Lagoon Disch 6-301804 Brier Creek 6-410914
Lagoon Disch 6-301804 Brier Creek 6-410914
Lagoon Disch 6-301804 Brier Creek 6-410914
QC Batch Method
SM 9223, Colilert SM 9223, Colilert SM 9223, Colilert
EPA 351.2 EPA 351.2
EPA 353.2 EPA 353.2
SM 4500-NH3 H SM 4500-NH3 H
SM4500-P B SM4500-P B
QC Batch
135459 135459 135459
639572 639572
135882 135882
135701 135701
135602 135602
Analytical Method SM 9223, Colilert SM 9223, Colilert SM 9223, Colilert EPA 351.2 EPA 351.2
SM 4500-P E SM 4500-P E
Analytical Batch 135460 135460 135460 640006 640006
135671 135671
Date: 02/27/2020 04:37 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, LLC.
Page 16 of 18
EPA Inspection Report - 54 of 81
Page 17 of 18
EPA Inspection Report - 55 of 81
Page 18 of 18
EPA Inspection Report - 56 of 81
Ogle Cattle Co. Inspection Date 2/18/20
Appendix 3 Quality Assurance Project Plan
EPA Inspection Report - 57 of 81
6EN QUALITY ASSURANCE PROJECT PLAN
Montague County, TX CAFOs
Feedlot and Livestock Auction in Montague County, Texas
Project Identifier: Feedlot and Livestock Auction in Montague County, TX - CAFO Sampling Inspections
Prepared by: Juan Ibarra and Carl Wills
6ECD-WA Prepared for: U.S. Environmental Protection Agency Region 6 Compliance Assurance and Enforcement Division (6EN) 1445 Ross Avenue Dallas, TX 75202-2733
February 14, 2020
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EPA Inspection Report - 59 of 81
Montague County, TX CAFOs Version 02
February 14, 2020 Page 3
A.2 Table of Contents
SECTION A - PROJECT MANAGEMENT..................................................................... 2 A.1 Title of Plan and Approval ................................................................................ 2 A.2 Table of Contents .............................................................................................. 3 A.3 A.4 Project Organization and Distribution List ............................................... 4 A.5 Problem Definition and Background ............................................................... 5 A.6 Project/Task Description .................................................................................. 6 A.7 Quality Objectives & Criteria ............................................................................ 8 A.8 Special Training/Certification........................................................................... 8 A.9 Documents and Records .................................................................................. 9
SECTION B - DATA GENERATION & ACQUISITION ................................................ 10 B.1 Sampling Process Design (Experimental Design)........................................ 10 B.2 Sampling Methods .......................................................................................... 12 B.3 Sampling Handling & Custody ....................................................................... 12 B.4 Analytical Methods.......................................................................................... 13 B.5 Quality Control ................................................................................................ 16 B.6 Instrument/Equipment Testing, Inspection, and Maintenance .................... 16 B.7 Instrument/Equipment Calibration and Frequency ...................................... 17 B.8 Inspection/Acceptance of Supplies & Consumables ................................... 17 B.9 Data Acquisition Requirements for Non-Direct Measurements .................. 17 B.10 Data Management.......................................................................................... 17
SECTION C - ASSESSMENT AND OVERSIGHT ....................................................... 18 C.1 Assessments and Response Actions............................................................ 18 C.2 Reports to Management ................................................................................. 18
SECTION D - DATA VALIDATION AND USABILITY ................................................. 18 D.1 Data Review, Verification, and Validation ..................................................... 18 D.2 Verification and Validation Methods.............................................................. 19 D.3 Reconciliation with User Requirements ........................................................ 19
List of Tables Table A.1 Roles & Responsibilities/Distribution List................................................... 4 Table B.1 Samples by Matrix ................................................................................... 11 Table B.4 - Analytical Methods, Preservatives and Containers for Samples............15
List of Figures Figure A.1 Project Organization Chart ....................................................................... 5 Figure B.3. Official Chain of Custody Example ........................................................ 14
Appendices Appendix A: Facility Maps .................................................................................... 20
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Montague County, TX CAFOs Version 02
February 14, 2020 Page 4
A.3 A.4 Project Organization and Distribution List
The individuals participating in the project and their specific roles and responsibilities are shown below. These individuals will receive copies of the approved Quality Assurance Project Plan (QAPP) and subsequent revisions:
Table A.1 Roles & Responsibilities/Distribution List
Individual(s) Assigned: Responsible for:
Collin Martin
EPA, Region 6 214-665-8380
Paul James
EPA, Region 6 214-665-6445
Melissa McCollough
Pace Analytical 2657 Gravel Dr. Ft Worth, TX 76118 972-727-1123 817-335-1186
Barbara McCray-OSU SWFAL 048 Agricultural Hall Stillwater, OK 74078 Phone: 405-744-6630 FAX: 405-744-9575
Juan Ibarra
EPA, Region 6 214-665-8380
Jack Arias EPA, Region 6 214-665-8154
Chelsey Sherwood EPA, Region 6 214-665-6452
Lead Inspector / Project Manager Quality Assurance Officer
Laboratory Point of Contact / Project Manager
Laboratory Point of Contact / Project Manager
Inspection/Sampling Team Member(s)
Esteban Herrera, Section Chief, (6EN-WC) Team Manager
Authorized to: Project Decisions, Lead and Assist Team Member(s), Collect and Assess Data Review and Approve QAPP Water samples Lab coordination for scheduling, analyses, validation, and deliverables.
Soil samples Lab coordination for scheduling, analyses, validation, and deliverables
Inspect / Sample / Collect Data
Oversee Overall Project
EPA Inspection Report - 61 of 81 Figure A.1 Project Organization Chart
Montague County, TX CAFOs Version 02
February 14, 2020 Page 5
Team Manager
For current 6EN Organization Chart, click on the following link: http://region6a.epa.gov/intranet/org/6en.pdf
A.5 Problem Definition and Background
Problem(s) to be resolved, decision(s) to be made and/or hypothesis to be tested:
The objective of the inspection is to clearly understand and document each Confined Animal Feeding Operation's (CAFO) waste management practices and implementation of their Nutrient Management Plan (if applicable). If a discharge of liquid waste or contaminated storm water run-off to a waterway is observed, it will be sampled and submitted for analysis. Streams or ponds at a facility may also be sampled. The number of water samples taken during each inspection will be based on site specific conditions encountered at the time of the inspection. During the inspection, water bodies on and nearby the facility should be examined for their characteristics in order to define waters of the United States.
If unlawful discharges of pollutants under Section 301(a) of the Act, 33 U.S.C. 1311(a) or other permit violations are documented, appropriate orders for corrective action will be issued.
Historical & background information:
CAFOs in Montague County (including a Livestock Auction), Texas are suspected contributors of pathogen (E. coli and other bacteria) and nutrient contamination to waters. Many streams and rivers in these areas are impacted for bacteria and are listed on the State's 303 (d) list. Potentially impacted waterways include Brier Creek and Lake Amon G. Carter which serves as a drinking water source for 801 people in Montague County.
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Montague County, TX CAFOs Version 02
February 14, 2020 Page 6
Prior inspections conducted by EPA and TCEQ have shown that CAFO operations can mismanage lagoon wastewaters, manure storage, and land application in such a way as to discharge nutrient and pathogen laden wastewater runoff to Waters of the U.S. Other CAFO operations have been found to have unpermitted discharges from cattle pens, employee mobile home site septic lines, land application sites, and various production areas located at the sites. Other general issues common to CAFOs include manure and wastewater misapplication (violation of the best management practices), mortality mismanagement, the lack of adequate lagoon storage facilities, and unpermitted discharges from the production areas. These CAFO waste mismanagement issues can result in off-site discharges with elevated concentrations of bacteria and nutrients, such as phosphorus and nitrogen (NO3 and NH4). Other problems include inadequately maintained or unutilized nutrient management plans, over application to the land application fields resulting in high nutrient levels, and a lack of recent soil analysis contributing to land application that does not meet the requirements of a nutrient management plan.
A.6 Project/Task Description
Samples of discharges from either a CAFO or Livestock Auction that reach a waterway will be taken as part of the facility inspections. The samples will be analyzed for the wastewater parameters, and possibly the soil parameters, listed in Table B. 4. The site names and locations are listed in Appendix A.
This QAPP has been prepared to address: These samples will provide information to aid in determining if lagoon mismanagement, land application or any other operation at these facilities could or have adversely affected surface water quality within Waters of the U.S. The results of the sampling inspections may be used to compel producer compliance agreements and to provide compliance assistance by EPA, in cooperation with other State and Federal partners. The potential for future enforcement actions are also possible.
The work to be performed includes: Objectives include the collection of wastewater discharge samples from cow pens, manure storage areas, production areas, lagoons, at the point that the discharge would potentially impact Waters of the U.S. with nutrients (i.e. nitrogen components and phosphorus) or bacteria. We may also collect contaminated runoff samples that enter a waterway from areas to which manure or wastewater has been improperly applied or improperly stored. Additionally, soil samples may be collected in areas where past discharge impact has been noted or at runoff discharge routes toward a waterway.
All enforcement wastewater samples will be hand delivered by EPA Region 6 staff to Pace Analytical Services (laboratory) Gravel Drive, Fort Worth, Texas. The laboratory
EPA Inspection Report - 63 of 81
Montague County, TX CAFOs Version 02
February 14, 2020 Page 7
will provide proper storage, extraction, analysis, reporting and disposal of the samples provided. Soil samples will be shipped to the OSU laboratory for proper storage, extraction, analysis reporting and disposal of the samples provided.
List samples/measurements to be collected/made and data to be obtained:
All wastewater sample analyses will be performed per the requirements of 40 CFR 136, by Pace Analytical. Parameters to be analyzed include TKN, Ammonia-N, Nitrate/NitriteN, Total Nitrogen, Total Phosphorus and E. coli. During this EPA field mobilization, it is assumed that around 4 sample sets will be collected for laboratory analyses. Samples will be taken if an unpermitted discharge enters a stream, river or other waterway.
Soil samples will be collected based on field observations and records (e.g., visible staining, topography, release reports, other facility records and possible flowpath(s)). Soil samples will be collected from the surface (0.0 to 0.01-foot interval) with each being a grab of enough material to fill a soil sampling bag provided by the excepting laboratory for each location. Each grab sample be collected with a properly decontaminated stainless-steel spoon or an unused and individually wrapped plastic scoop with each only being used only for each grab sample location. Then each scoop or spoon full will be placed in the soil sampling until enough soil is collected to fill the bag. Additionally, the grab samples be collected both up- and down-gradient of the discharge location. Additional, locations will be determined in the field, if necessary.
All soil sample analyses will be performed for the analytes listed in Table B.1 per the requirements by methods established in the QA Plan for Oklahoma State University - Soil, Water and Forage Analytical Laboratory (SWFAL).
Special personnel or equipment requirements:
Equipment used for sample collection will be EPA sterile bacteria bottles and certified clean containers, or containers provided by the laboratory. Personnel will be Credentialed Inspectors that meet the training requirements for CAFO Inspections, and the Safety Requirements required for field inspection work.
Proposed work schedule:
0700-1600 during one work-week in February 2020.
Products to be produced:
Laboratory data that is supported by appropriate QA/QC which will be included into a facility inspection report.
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A.7 Quality Objectives & Criteria
This inspection will be conducted under the authority of Section 308 of the Clean Water Act, and in accordance to 40 CFR 136 - Guidelines Establishing Test Procedures for the Analysis of Pollutants. The soil sample analyses will be performed per the requirements by methods established in the QA Plan for Oklahoma State University - SWFAL.
To support this requirement, EPA has developed a systematic planning process based on a graded approach for environmental decision making called the Data Quality Objectives (DQO) Process. The DQO Process is the Agency's preferred planning process and provides quality objectives and performance criteria based on the user's determination of tolerable error in the results. For details on the DQO Process and guidance on how and when it may be used, see the "Guidance on Systematic Planning Using the Data Quality Objectives Process (EPA QA/G-4) (EPA, February 2006)." This process has limited applicability to most enforcement inspection activities, since generally only Special Projects lend themselves to development of formal DQOs and defining of error limits, hypothesis testing, etc.
All data collected shall be in accordance with the appropriate EPA methodologies and protocols found in the appropriate regulatory guidance. The data shall be used to determine the following:
1. The potential water quality impact by a CAFO or Livestock Auction that is discharging process wastewater to a Water of the U.S.
The data must meet the approved method accuracy requirements such as those found in Industry-specific methods (40 CFR 136). The soil sample analyses will be performed per the requirements by methods established in the QA Plan for Oklahoma State University - SWFAL. All supporting QA/QC information shall be provided. The data may be used to support any future enforcement actions.
A.8 Special Training/Certification
Field personnel should have completed the Health and Safety 8-Hour Training that meets the 29 CFR 1910.120(e)(8) requirement of 8-hours of refresher training for hazardous waste site workers. Field personnel should also have completed the mandatory training under EPA Order 3500.1 for Inspectors required to hold Clean Water Act Inspector credentials. All non-credentialed personnel (e.g. inspectors in training) must meet the 29 CFR 1910.120(e)(8) requirements, and should be in accompanied by credentialed personnel while inspecting/sampling at the facility/site. Inspection personnel must be familiar with and follow bio-security procedures.
Additional Special Training: EPA course on Defensible Sampling and on the job training with senior inspectors.
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A.9 Documents and Records
The records for this project will include miscellaneous correspondence, field notes, laboratory analytical reports, photo logs, and inspection reports. All laboratory reports will be submitted to the EPA Lead Inspector/Project Manager. Field notes will include observations about facility conditions at the site(s) where samples are collected. Any noteworthy deviation from the procedures specified in the QAPP will be recorded in the field activity logs. Laboratory analytical reports will be generated for all of the samples received by the laboratory. Each set of samples will include a chain of custody form signed by the samplers and the laboratory recipient. All samples will be delivered by an EPA Field Team Member.
The EPA Project Manager will disseminate copies of the QAPP to the people listed in the distribution list once it is approved. Any revisions to the QAPP will be numbered sequentially. It will be the responsibility of the EPA Project Manager to ensure that each person on the distribution list receives copies of any revisions.
All EPA records and documents from this project will be handled according to the following EPA Region 6 Field Activities Quality System Procedures:
Records Management - R6PROC-003 Management of Sampling and Environmental Data - R6PROC-004 Field Documentation - R6PROC-005 Field Equipment Inventory and Management - R6PROC-006 Field Inspections and Investigations - R6PROC-007 Field Activities Report Preparation and Distribution- R6PROC-008
The designated and/or contracted laboratory will manage the testing and original raw data from this project (both hard copy and electronic) in accordance with their established and accredited procedures. Any deviations from these procedures shall be approved by the EPA Project Manager before implementation.
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SECTION B - DATA GENERATION & ACQUISITION
B.1 Sampling Process Design (Experimental Design) Describe the experimental data generation or data collection design for the project:
The decision on whether or not to collect a sample will be contingent upon the following factors:
1. If the CAFO or Livestock Auction is discharging process wastewater from the production area (including the lagoon, milking parlor or land application site) into a creek, stream or river, then a sample will be taken of that discharge as it enters the waterway.
Because these samples are to be the result of an inspection and a one-time inspection/sampling event, a detail process design is not feasible or appropriate. However, the procedures to be followed from initiation to final report could be described as followed:
Step 1:
Step 2: Step 3: Step 4:
Lead Inspector assembles sampling equipment, chain of custody forms, pre-inspection plan, QAPP, sampling equipment/containers, ice chests, etc. and notifies laboratory to expect samples of a particular matrix for a specific analysis (see Table B.1).
Inspection Team proceeds to field for observation, sample collection if the situation warrants.
Inspection Team transports or ships sample(s) along with chain of custody forms to the laboratory for analytical testing.
Analytical results received from laboratory, inspector evaluates data, attaches to report, and takes any required action.
Types and number of samples required: See Table B.1.
Sampling network design & rationale for design: To be determined in the field.
Sampling locations & frequency of sampling: To be determined in the field. Each CAFO site will be individually evaluated based on their operational condition at the time of the inspection. If the CAFO is discharging to a Waters of the U.S., then the Table B.1. Samples by Matrix will be initiated for those sites. The total number of samples is unknown until a determination is made in the field.
Sample matrices: See Table B.1.
Classification of measurement parameters: Critical - For environmental compliance and potential subsequent Enforcement Action.
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Validation study information, for non-standard situations: N/A: Standard validation Table B.1 Samples by Matrix
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# of Matrix Samples # of Field Blank** # of Trip Blank* # of Blind Duplicate
# of MS/MSD Total # of Samples
Matrix
Analysis
Example: TCLP RCRA 8 Metals SW846 6010C/7471
Water
6
1
0
0
*** 7 E coli
Water
6
0
0
0
*** 6 TKN
Water
6
0
0
0
*** 6 Ammonia - N
Water
6
0
0
0
*** 6 Nitrate/Nitrite - N
Water
6
0
0
0
*** 6 Total N
Water
6
0
0
0
*** 6 Total Phosphorus
Soil
10 0
0
0
*** 10 Routine Analysis
Soil
10 0
0
0
*** 10 Ammonium - N
Soil
10 0
0
0
*** 10 Organic Matter
Soil 10 0 0 0 *** 10 Organic Carbon and Total Nitrogen
Note: *Trip blanks are for VOC analyses only. ** Field blanks column may also include rinsate blanks. Samples include one sample upgradient of the facility and one sample downgradient of the facility. *** Lab will perform MS/MSD as part of their required QA/QC.
Typical Analytical Method No.
Volatile Organics by GC/MS SW846 - 8260B EPA500 - 524.2 EPA600 - 624 CLP - VOA - MC CLP - VOA - LC Std. Methods 6210B Std. Methods 6210C Std. Methods 6210D
Volatile Organics by GC SW-846 - 8021B EPA500 - 502.2 EPA600 - 601 EPA600 - 602 Std. Methods 6220B Std. Methods 6220C Std. Methods 6230B Std. Methods 6230C
Semi-Volatile Organics by GC/MS SW846 - 8270D EPA500 - 525.2 EPA600 - 625 CLP - SVOA - MC CLP - SVOA - LC CLP - PEST - LC Std. Methods 6410
PAH SW846 - 8310 (HPLC)
Inorganic Analytes SW- 846 7000 Series (AA) SW- 846 6010C (ICP) SW- 846 6020A (ICP-MS) EPA 200 Series (AA) EPA 200.7 (ICP) EPA 200.8 (ICP-MS) CLP Inorganic Method (ICP) CLP Inorganic Method (AA) Std Methods 3000 Series (AA) Std. Method 3120 (ICP)
Herbicides SW846 - 8151A EPA 500 - 515.4 EPA 500 - 515.2 Std. Methods 6640
Pesticides & PCBs SW846 - 8081B SW846 - 8082A EPA500 - 508 EPA600 - 608 CLP-PEST- MC Std. Methods 6630
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Std. Methods 6230D
B.2 Sampling Methods
Identify sample collection procedures:
Samples will be collected from the production area discharge point into the waterway. Samples will be collected directly into the sample container.
Identify sampling methods and equipment:
Sampling methods and regulatory citation: The analytical methods, sample containers, holding times, and sample preservation requirements are presented in Table B.4 and apply to EPA Sampling Methods: 40 CFR 136
Sampling equipment available during the inspection/sampling event: None required, as samples will be collected directly into the sample containers at the point of the production area discharge into the waterway (creek, stream or river).
Implementation requirements: Will be based on the Lead Inspector's field observations, field conditions, facility operations and/or timing.
Sample preservation requirements: See Table B.4 - Analytical Methods, Preservatives and Containers for Samples
Decontamination procedures: Decon not required, as we will use disposable PPE and dedicated (One-Time-Use) sampling containers.
Any support facilities needed: At this time, no support appears to be needed.
Specific performance requirements for the sampling methods: Detection limits are defined in contract laboratory's QA manual. Reporting limits are defined in contract laboratory's QA manual. These limits will be verified to assure that they will not exceed the regulatory limit of no discharge for CAFOs.
If a failure in the sampling or measurement system occurs, the Lead Inspector/Project Manager must be notified. The Quality Assurance Officer and/or Laboratory Point of Contact will act as advisors to the Lead Inspector/Project Manager. The Lead Inspector/Project Manager will be responsible for any decision concerning corrective action. Corrective action in the field or in the laboratory will be documented in the field notes and/or in the final laboratory analytical report based on the action(s) required.
B.3 Sampling Handling & Custody
The date and time of sample collection will be recorded on the field activity log and on all samples: additionally, that information will be recorded on the Chain of Custody (COC) form. The desired analytical tests to be performed and any preservatives used will also be noted on the COC form. An example COC format is attached in Figure B.3.
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Prior to shipment, all samples shall be in custody with the inspection/sampling team. Sample team shall keep all samples in an environment that maintain its preservation (e.g., inside cooler(s) with double bagged ice and packing material) In lieu of tied on tags, stick on sample labels may be used as long as they contain the following information: sampler name, date, time, station location, sampler signature, sample # and analysis requested. Custody seals shall be used on each sample container and sample coolers, unless samples are hand delivered to the designated laboratory by a member of the inspection/sampling team as along as the custody chain is not breached.
B.4 Analytical Methods
Identify analytical methods to be followed (with all options) & required equipment: See Table B.4 - Analytical Methods, Preservatives and Containers for Samples.
Specify any specific method performance criteria: The laboratory's NELAC Certification defines all sample parameter performance criteria, as well as the laboratory's QA manual.
Provide validation information for non-standard methods: N/A
Identify procedures to follow when failures occur: If failure(s) occur during the analysis, the Laboratory Point of Contact will contact the Lead Inspector/Project Manager within 24-hours, and communicate the failure and identify potential corrective remedies. The Lead Inspector/Project Manager will make the determination on the remedy. The failure(s) and corrective remedies will be document via email and cc: the first-line supervisor and the QA Officer.
Identify individuals responsible for corrective action and appropriate documentation: Juan Ibarra (EPA Project Manager), and Melissa McCullough (Laboratory Project Manager).
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Table B.4 - Analytical Methods, Preservatives and Containers for Samples
Sample # of Matrix Samples
Analyte / Analyte Sweep
Analytical Method No.
Holding Time (Days)
TCLP
Size and Type of Containers
Water
6
E. coli
SM 9223 B
8 hours
100-mL sterile coliform bottle
Water
1
E. coli (blank)
SM 9223 B
8 hours
100-mL sterile coliform bottle
Water
6
TKN
SM 4500 N-organic B 28
250-ml Polyethylene
Water
6
Ammonia - N
SM 4500 NH3-H
28
250-mL polyethylene
Water
6
Nitrate/Nitrite - N
EPA 353.2
28
250-mL polyethylene
Water
6
Total Nitrogen
calculation
28
250-ml Polyethylene
Water
6
Total Phosphorus
SM 4500 P-E
28
250-mL polyethylene
Soil 10 Routine Analysis QA Plan OSU- 28 SWFAL
Lab. Provided Soil Sampling Bag
Soil
10
Ammonium-N
QA Plan OSU- 28 SWFAL
Lab. Provided Soil Sampling Bag
Soil
10
Organic Matter
QA Plan OSU- 28 SWFAL
Lab. Provided Soil Sampling Bag
Soil 10 Organic Carbon & QA Plan OSU- 28
Total Nitrogen
SWFAL
Lab. Provided Soil Sampling Bag
Typical Analytical Method No.
# of Containers per Sample
1
1
1 Combined
1 Combined
1 Combined
1 Combined
1 Combined
1 - Soil Combined
1 - Soil Combined
1 - Soil Combined
1 - Soil Combined
Preservatives
Ice (6C)
Ice (6C) H2SO4 w/ Ice
(6C) H2SO4 w/ Ice
(<6 C) H2SO4 w/ Ice
(<6 C) H2SO4 w/ Ice
(6C) H2SO4 w/ Ice
(6C) Ship Dry
Ship Dry
Ship Dry
Ship Dry
Volatile Organics by GC/MS SW846 - 8260B EPA500 - 524.2 EPA600 - 624 CLP - VOA - MC CLP - VOA - LC Std. Methods 6210B Std. Methods 6210C Std. Methods 6210D
Volatile Organics by GC SW-846 - 8021B EPA500 - 502.2 EPA600 - 601 EPA600 - 602 Std. Methods 6220B Std. Methods 6220C Std. Methods 6230B Std. Methods 6230C Std. Methods 6230D
Semi-Volatile Organics by GC/MS SW846 - 8270D EPA500 - 525.2 EPA600 - 625 CLP - SVOA - MC CLP - SVOA - LC CLP - PEST - LC Std. Methods 6410 PAH (HPLC) SW846 - 8310
Inorganic Analytes SW- 846 7000 Series (AA) SW- 846 6010C (ICP) SW- 846 6020A (ICP-MS) EPA 200 Series (AA) EPA 200.7 (ICP) EPA 200.8 (ICP-MS) CLP Inorganic Method (ICP) CLP Inorganic Method (AA) Std Methods 3000 Series (AA) Std. Method 3120 (ICP)
Herbicides SW846 - 8151A EPA 500 - 515.4 EPA 500 - 515.2 Std. Methods 6640
Pesticides & PCBs SW846 - 8081B SW846 - 8082A EPA500 - 508 EPA600 - 608 CLP-PEST- MC Std. Methods 6630
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B.5 Quality Control
Identified below are a number of quality control samples that will be collected.
Trip Blanks: N/A
Field Blanks
Number of Blank(s): Each day, one or more samples will be taken by the sampling team for E. coli analysis. Type II reagent grade deionized water from the Addison COOP wet lab and placed into a certified clean cubitainer, and taken into the field in this container.
Equipment Rinsate Blanks
None required as no equipment is planned to be used.
Rinsate Type: N/A
Describe Preparation: N/A
Blind Replicate or Duplicate Samples
Duplicate samples will be selected by the laboratory for their QC analysis as required by their QA program and protocols, and selected at their choosing.
Sample Matrix: Water
Location: N/A
Matrix Spike (MS) / Matrix Spike Duplicate (MSD) Samples
MS/MSD samples will be selected by the laboratory for their QC analysis as required by their QA program and protocols, and selected at their choosing. Sample Matrix: Water Location: To be determined by the laboratory QA Manager.
B.6 Instrument/Equipment Testing, Inspection, and Maintenance
EPA field personnel will not utilize any field instruments during these inspections.
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B.7 Instrument/Equipment Calibration and Frequency
Identify all tools, gauges, instruments, and other sampling, measuring, and test equipment used for data generation or collection activities affecting quality that must be controlled and calibrated: None
Describe or reference how calibration will be conducted using certified equipment and/or standards with known valid relationships to nationally recognized performance standards. If no such nationally recognized standards exist, document the basis for the calibration: N/A
B.8 Inspection/Acceptance of Supplies & Consumables
The EPA Project Manager will be responsible for inspecting sample containers prior to leaving for the inspection. Only new sample containers accompanied by the manufacturer's certification of pre-cleaning will be used. The sample containers will be inspected for cracks, ill-fitting lids, or other defects prior to use and will be discarded if defects are found.
B.9 Data Acquisition Requirements for Non-Direct Measurements
Records may be collected during the inspection/sampling event to document activities at the facility. Documents may be requested for a period of up to five years prior to the inspection/sampling event. These records will be used for determining the facility's compliance with the requirements of CWA.
B.10 Data Management
Data for this project will be produced both onsite and at the designated/approved Laboratory. Laboratory data will be submitted to the EPA Project Manager and will be included in the subsequent inspection report. Data collected during the inspection may be designated as Confidential Business Information (CBI) by representatives of CRS. For any information for which a CBI claim is made that information will be handled in accordance with the provisions specified for CWA CBI. All records and documents generated during this project will be handled in accordance with EPA's "Standard Operating Procedures for Record and Information Management"
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SECTION C - ASSESSMENT AND OVERSIGHT
C.1 Assessments and Response Actions
Documentation and analytical results collected during this project will be evaluated to determine the compliance status as it applies to the facility's requirements under CWA. Results of this evaluation will determine what action, if any, the Agency should take in response to any Areas of Concern identified during the inspection. The magnitude and breadth of any concerns identified will determine the appropriate response on the part of the Agency which includes but is not limited to the issuance of administrative orders, administrative penalty orders, or judicial referral.
C.2 Reports to Management
This project will result in the generation of an inspection report which will include an inspection narrative, a photographic log, documents collected during the inspection, and analytical reports for all samples collected, if any.
SECTION D - DATA VALIDATION AND USABILITY
D.1 Data Review, Verification, and Validation
Data will be accepted if they meet the following criteria:
1. Field logs are complete.
2. Prior to releasing the analytical data, the laboratory staff will review both the sample and QC data to verify sample identity, instrument calibration, quantitation limits, dilution factors, numerical computations, accuracy of transcriptions, and chemical interpretations. In addition, the QC data are tabulated and the results reviewed to ascertain whether they were within the project-required limits for accuracy and precision. Any non-conforming data will be discussed in the data package case narrative. If necessary, qualifiers are applied based on this information. The laboratory staff review will consist of a Peer review, a Senior Chemist review, a Point of Contact review, and a QA Officer review. The review will follow the US EPA National Functional Guidelines for Organic Methods Data Review (SOM02.2), US EPA National Functional Guidelines for Inorganic Data Review (ISM02.2).
3. Field data is reviewed to ensure that they are complete; that sample collection information is thoroughly documented; and that any deviations from the QAPP are noted.
4. Actual sampling locations are documented in the inspection logbook. Locations were determined using GPS instrumentation, linear measurements, and/or photographic references, and will be verified against DigitalGlobe aerial photos and USGS Topographic maps.
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5. Sample handling procedures are documented on chain of custody forms.
Any deviations from the QAPP are to be reported in the field logs. The Lead Inspector/Project Manager will verify the contents of these logs. If the data fails to meet the criteria they will be flagged as estimated. Any flagged data will be discussed with management to determine if the data point will be rejected and re-sampling done.
D.2 Verification and Validation Methods
Field data will be validated by the Lead Inspector/Project Manager, and any problems identified during this project will be documented in the field logs. The laboratory supervisor will validate laboratory data according to methods established in their QA Plan.
The Lead Inspector/Project Manager will review and verify field logs and analytical data reports. Any problems or deviations identified will be discussed with the project team and the first-line supervisor to determine corrective action measures.
D.3 Reconciliation with User Requirements
The designated laboratory will provide a final laboratory report along with the supporting electronic data in a usable spreadsheet format. All laboratory bench sheets and equipment calibrations will be maintained by the designated laboratory and will be available upon request. The data will be used to support any future enforcement actions or litigation.
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Appendix A: Facility Maps
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Ogle Cattle Co and Bowie Texas Livestock Sale Barn Inspection Date 02/18/2020
Fig 1. USGS Aerial Map showing Ogle Cattle Co and Bowie Texas Livestock Sale Barn.
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Ogle Cattle Co and Bowie Texas Livestock Sale Barn Inspection Date 02/18/2020
Fig 2. USGS Aerial Map showing Ogle Cattle Co and Bowie Texas Livestock Sale Barn. The red colored pin indicates the location of facilities, blue line indicates intermittent stream and a relative permanence, red lines indicates potential pathways of discharge, and blue dots indicates elevation.
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Ogle Cattle Co and Bowie Texas Livestock Sale Barn Inspection Date 02/18/2020
Fig 3. USGS Topographic Map showing Ogle Cattle Co and Bowie Texas Livestock Sale Barn. The red colored pin indicates the location of facilities, blue line indicates intermittent stream and a relative permanence, red lines indicates potential pathways of discharge, and blue dots indicates elevation.
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Ogle Cattle Co and Bowie Texas Livestock Sale Barn Inspection Date 02/18/2020
Fig 4. USGS Topographic Map showing Ogle Cattle Co and Bowie Texas Livestock Sale Barn. The red colored pin indicates the location of facilities, blue line indicates intermittent stream and a relative permanence, red lines indicates potential pathways of discharge, and blue dots indicates elevation.
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Ogle Cattle Co and Bowie Texas Livestock Sale Barn Inspection Date 02/18/2020
Fig 5. USGS Hydro-NHD Map showing Ogle Cattle Co and Bowie Texas Livestock Sale Barn. The red colored pin indicates the location of facilities, blue line indicates intermittent stream and a relative permanence, and blue dots indicates elevation.