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Tri-Lateral Monitoring Systems Audit – NTMWDAngela Kilpatrick -Trinity River Authority
Allen Pappas – Previously of Red River Authority
TCEQ CRP FY2017 Statewide Partner Meeting – September 285, 2016
Presentation Overview
• What is Sub-Participant Oversite?
• A Unique Situation
• The Tri-Lateral Monitoring Systems Audit Approach
• Outcomes
What is Sub-Participant Oversight?
Basin Planning Agencies are required to oversee the activities addressed in their QAPPs and must conduct formal
audits of all sub-participants who conduct field monitoring. If all work is
performed by the Basin Planning Agency (i.e. there are no sub-
participants participating in the Basin’s CRP program), these audits are not required. Negotiate the timing and scope of oversight activities, and
document in the QAPP.
What is Sub-Participant Oversight?
• There are two acceptable types of sub-participant field monitoring audits:
• readiness reviews, and • monitoring systems audits.
• Perform at least one audit at the sub-participant’s office, field station, or other appropriate location at least once during each contract cycle (biennium), in the case of on-going projects; or once during a project’s lifetime, in the case of short-lived special studies.
A Unique Situation
• Historically, the North Texas Municipal Water District (NTMWD) had been in one (1) CRP QAPP
• Beginning in FY2016-17, NTMWD had interest in conducting CRP monitoring in multiple river basins, and multiple QAPPs including:
• Red River Authority of Texas• Trinity River Authority• Sulphur River Basin Authority
A Unique Situation
• Based on current TCEQ CRP Task 2 Guidance, each of the three (3) river authorities should have conducted some form of “sub-participant oversight”:
• TRA / SRBA – Readiness Review• RRA – Monitoring Systems Audit
• High duplication of effort and potential for other negative ramifications:
• Differences in how the audit(s) were conducted• Differences in finding(s) from audit(s)• Administrative burden could create delays in data
collection
• Tri-Lateral MSA approach
Tri-Lateral MSA Approach
Pre-Audit• Conference call to discuss Tri-Lateral
approach • TCEQ CRP Project Managers• TCEQ CRP Quality Assurance• River Authority Project Managers
• Developed a plan• Pre-Audit / Audit / Post-Audit
• Assigned “Lead Partner Role”• Red River Authority• Responsible for organizing MSA and
“represented” CRP Partners to simplify paperwork
Tri-Lateral MSA Approach
Pre-Audit• NTMWD was contacted to inform them of
the Tri-Lateral approach
• NTMWD was notified by the “Lead Partner” in writing of the MSA
• All CRP partners were included on the letter and CC’d when documents were emailed to NTMWD
• Conference call to discuss how to handle the actual audit when on-site
• Areas of interest• Documentation needs/wants
Tri-Lateral MSA Approach
Audit Process• Entry meeting amongst staff to discuss
scope, intent and goals of the MSA and to outline the proposed MSA schedule
• TRA representative• SRBA representative• RRA representatives• NTMWD representatives
• Discuss any questions/concerns before beginning
Tri-Lateral MSA Approach
Audit Process• Reviewed at NTMWD Facility:
• Review of previous findings• Sample receiving and storage• Bacteriological sample analysis• Document control / record keeping• Sonde calibration (pre/post), calibration
records, maintenance• Sample containers (prep/storage/cleaning)
• Reviewed in the field:• Mock event to include all aspects of data
collection (field measurements, flow, sample collection so forth)
Tri-Lateral MSA Approach
Audit Process• Exit meeting amongst staff to discuss the
MSA report/response process:• TRA representative• SRBA representative• RRA representatives• NTMWD representatives• NTWMD management
• All potential findings were discussed
• Discuss any questions/concerns before departing
Tri-Lateral MSA Approach
Post-Audit• Audit findings and documentation was
compiled by “Lead Partner” and distributed to all partners and TCEQ
• Additional information/notes from partners was compiled into a final document and findings were prepared
• Findings were submitted to TCEQ for review
Tri-Lateral MSA Approach
Post-Audit• Once findings were approved by TCEQ and
all partners/TCEQ agreed with MSA report, NTMWD was notified
• This process was greatly hindered due to the nature of one particular finding (flow measurement method/procedure)
• This finding was discussed at length between partners and TCEQ which led to the report being delayed
• Initial report was sent to NTMWD on 11/04/15
• Approximately 43 days after MSA was conducted
Tri-Lateral MSA Approach
Post-Audit• NTMWD responded on 12/18/15
• Approximately 45 days after the MSA report
• This was largely impacted by two factors:• There was still ongoing discussion amongst
partners, NTMWD and TCEQ regarding the audit finding related to flow measurement method/procedure
• NTMWD was concerned about data-loss impact on affected parameter codes for data that had already been submitted/accepted by TCEQ
Tri-Lateral MSA Approach
Post-Audit• After much discussion a revised MSA
report was sent to NTMWD on 01/26/16 (40 days)
• NTMWD responded on 02/19/16 (25 days)
• After much discussion, the audit was closed on 03/21/16 (32 days)
• The audit process lasted approximately 181 days since the actual MSA was held on 09/23/15
Tri-Lateral MSA ApproachInitial
Discussion with TCEQ
Conference Call
Conference Call
Audit Notification
09/01/15
Tri-Lateral MSA 09/23/15
MSA Report 11/04/15
Audit Closure 03/21/16
NTMWD Response 12/18/15
Finding Discussion
Response Discussion
NTMWD Response 02/19/16
Response Discussion
Revised MSA Report
01/26/16
Outcomes
Positive Outcomes of the Tri-Lateral Approach• Prevented a “duplication of effort”• Reduced the administrative burden of CRP
on NTMWD• Ensured uniformity across CRP partners
Negative Outcomes of the Tri-Lateral Approach• Is very time intensive which can be difficult• Input from multiple partners slows the
process down• Audit findings impact participating partners
very differently
OutcomesPotential considerations going forward:• Consider revising TCEQ CRP Task 2 Guidance to clarify
scenarios that justify and/or require additional MSA activities in the same biennium
• Consider revising TCEQ CRP Task 2 Guidance to add language detailing the suggested audit process for sub-participants in multiple QAPPs
• Consider revising TCEQ CRP Task 2 Guidance to include addendums with example audit documents (audit notification, comment matrix, so forth)
• Consider revising the Monitoring Systems Audit Checklist to accurately reflect current field practices and TNI Standards
• Consider revisions to the SWQM Procedures Manual
