| Water Body Name: | Keys Creek (Marin County) |
| Water Body ID: | CAR2011203020210504043847 |
| Water Body Type: | River & Stream |
DECISION ID |
151717 |
Region 2 |
Keys Creek (Marin County) |
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| Pollutant: | Benthic Community Effects |
| Final Listing Decision: | Do Not List on 303(d) list (TMDL required list) |
| Last Listing Cycle's Final Listing Decision: | New Decision |
| Revision Status | Revised |
| Impairment from Pollutant or Pollution: | Pollutant |
| Regional Board Conclusion: | Benthic Community Effects are being considered for placement on the CWA section 303(d) List under sections 3.9 of the Listing Policy. Under section 3.9, additional lines of evidence (LOEs) associating the Benthic Community Effects decision with a water or sediment concentration of pollutants other than benthic-macroinvertebrate bioassessment or habitat assessment LOEs are necessary to place a water body on the 303(d) List for Benthic Community Effects. Two line(s) of evidence evaluating benthic-macroinvertebrate bioassessment data is/are available in the administrative record to assess this indicator. Two of two benthic-macroinvertebrate samples exceed the California Stream Condition Index (CSCI) impairment threshold. However, a minimum of two benthic-macroinvertebrate samples are needed to assess listing status. Based on the readily available data and information, the weight of evidence indicates that there is sufficient justification against placing Benthic Community Effects in this waterbody segment on the CWA section 303(d) List. This conclusion is based on the staff findings that: 1. The data used satisfies the data quality requirements of section 6.1.4 of the Policy. 2. The data used satisfies the data quantity requirements of section 6.1.5 of the Policy. 3. Two of two benthic-macroinvertebrate bioassessment samples had CSCI scores below 0.79. The available information is insufficient to determine whether the waterbody/pollutant combination should be placed on the 303(d) List of impaired waters at this time. 4. Pursuant to section 3.11 of the Listing Policy, no additional data and information are available indicating that standards are not met. |
| Regional Board Decision Recommendation: | After review of the available data and information, RWQCB staff concludes that the water body-pollutant combination should not be placed on the section 303(d) list. The readily available data and information is insufficient to determine, with the power and confidence of the Listing Policy, the applicable beneficial use support rating. |
| State Board Review of Regional Board Conclusion and Recommendation: | |
| State Board Decision Recommendation: | |
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| LOE ID: | 306982 | ||||
| Pollutant: | Benthic-Macroinvertebrate Bioassessments | ||||
| LOE Subgroup: | Population/Community Degradation | ||||
| Matrix: | Water | ||||
| Fraction: | None | ||||
| Beneficial Use: | Cold Freshwater Habitat | ||||
| Number of Samples: | 1 | ||||
| Number of Exceedances: | 1 | ||||
| Data and Information Type: | Benthic macroinvertebrate surveys | ||||
| Data Used to Assess Water Quality: | Water Board staff assessed data for 201WLK050 to determine beneficial use support and the results are as follows: 1 of 1 samples exceeded the threshold. CSCI scores were from 0.502292 to 0.502292. | ||||
| Data Reference: | California Stream Condition Index (CSCI) Scores for the 2024 Integrated Report for Region 2. | ||||
| SWAMP Data: | SWAMP | ||||
| Water Quality Objective/Criterion: | All waters shall be maintained free of toxic substances in concentrations that are lethal to or that produce significant alterations in population or community ecology or receiving water biota. In addition, the health and life history characteristics of aquatic organisms in waters affected by controllable water quality factors shall not differ significantly from those for the same waters in areas unaffected by controllable water quality factors. | ||||
| Objective/Criterion Reference: | Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2) | ||||
| Evaluation Guideline: | The California Stream Condition Index (CSCI) is a biological scoring tool that helps aquatic resource managers translate complex data about benthic macroinvertebrates found living in a stream into an overall measure of stream health. The CSCI score is calculated by comparing the expected condition with actual (observed) results (Rehn, A.C. et al., 2015). CSCI scores range from 0 (highly degraded) to greater than 1 (equivalent to reference). CSCI scoring of biological condition are as follows (per the scientific paper supporting the development of the CSCI scoring tool): greater than or equal to 0.92 = likely intact condition, 0.91 to 0.80 = possibly altered condition, 0.79 to 0.63 = likely altered condition, less than or equal to 0.62 = very likely altered condition. Sites with scores below 0.79 are considered to have exceeded the water quality objective for the aquatic life beneficial use. | ||||
| Guideline Reference: | Bioassessment in complex environments: designing an index for consistent meaning in different settings | ||||
| Spatial Representation: | Samples were collected from station 201WLK050. | ||||
| Temporal Representation: | Samples were collected from 4/17/2001 to 4/17/2001. | ||||
| Environmental Conditions: | |||||
| QAPP Information: | Data were collected using Surface Water Ambient Monitoring Program protocols | ||||
| QAPP Information Reference(s): | This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements. | ||||
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| LOE ID: | 306975 | ||||
| Pollutant: | Benthic-Macroinvertebrate Bioassessments | ||||
| LOE Subgroup: | Population/Community Degradation | ||||
| Matrix: | Water | ||||
| Fraction: | None | ||||
| Beneficial Use: | Cold Freshwater Habitat | ||||
| Number of Samples: | 1 | ||||
| Number of Exceedances: | 1 | ||||
| Data and Information Type: | Benthic macroinvertebrate surveys | ||||
| Data Used to Assess Water Quality: | Water Board staff assessed data for 201WLK030_SWAMP to determine beneficial use support and the results are as follows: 1 of 1 samples exceeded the threshold. CSCI scores were from 0.41977 to 0.41977. | ||||
| Data Reference: | California Stream Condition Index (CSCI) Scores for the 2024 Integrated Report for Region 2. | ||||
| SWAMP Data: | SWAMP | ||||
| Water Quality Objective/Criterion: | All waters shall be maintained free of toxic substances in concentrations that are lethal to or that produce significant alterations in population or community ecology or receiving water biota. In addition, the health and life history characteristics of aquatic organisms in waters affected by controllable water quality factors shall not differ significantly from those for the same waters in areas unaffected by controllable water quality factors. | ||||
| Objective/Criterion Reference: | Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2) | ||||
| Evaluation Guideline: | The California Stream Condition Index (CSCI) is a biological scoring tool that helps aquatic resource managers translate complex data about benthic macroinvertebrates found living in a stream into an overall measure of stream health. The CSCI score is calculated by comparing the expected condition with actual (observed) results (Rehn, A.C. et al., 2015). CSCI scores range from 0 (highly degraded) to greater than 1 (equivalent to reference). CSCI scoring of biological condition are as follows (per the scientific paper supporting the development of the CSCI scoring tool): greater than or equal to 0.92 = likely intact condition, 0.91 to 0.80 = possibly altered condition, 0.79 to 0.63 = likely altered condition, less than or equal to 0.62 = very likely altered condition. Sites with scores below 0.79 are considered to have exceeded the water quality objective for the aquatic life beneficial use. | ||||
| Guideline Reference: | Bioassessment in complex environments: designing an index for consistent meaning in different settings | ||||
| Spatial Representation: | Samples were collected from station 201WLK030_SWAMP. | ||||
| Temporal Representation: | Samples were collected from 4/17/2001 to 4/17/2001. | ||||
| Environmental Conditions: | |||||
| QAPP Information: | Data were collected using Surface Water Ambient Monitoring Program protocols | ||||
| QAPP Information Reference(s): | This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements. | ||||
DECISION ID |
143992 |
Region 2 |
Keys Creek (Marin County) |
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| Pollutant: | Temperature, water |
| Final Listing Decision: | Do Not List on 303(d) list (TMDL required list) |
| Last Listing Cycle's Final Listing Decision: | New Decision |
| Revision Status | Revised |
| Impairment from Pollutant or Pollution: | Pollutant |
| Regional Board Conclusion: | Insufficient information is available to determine beneficial use support for this waterbody-pollutant combination with the statistical power and confidence required by the Listing Policy. Beneficial use support will be reassessed in a future cycle, if more data are available. |
| Regional Board Decision Recommendation: | After review of the available data and information, RWQCB staff concludes that the water body-pollutant combination should not be placed on the section 303(d) list. The readily available data and information is insufficient to determine, with the power and confidence of the Listing Policy, the applicable beneficial use support rating. |
| State Board Review of Regional Board Conclusion and Recommendation: | |
| State Board Decision Recommendation: | After review of the available data and information, SWRCB staff concludes that the water body-pollutant combination should not be placed on the section 303(d) list because it cannot be determined if applicable water quality standards are not being exceeded. |
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| LOE ID: | 298874 | ||||
| Pollutant: | Temperature, water | ||||
| LOE Subgroup: | Pollutant-Water | ||||
| Matrix: | Water | ||||
| Fraction: | Not Recorded | ||||
| Beneficial Use: | Fish Migration | ||||
| Number of Samples: | 1 | ||||
| Number of Exceedances: | 0 | ||||
| Data and Information Type: | PHYSICAL/CHEMICAL MONITORING | ||||
| Data Used to Assess Water Quality: | Water Board staff assessed SWAMP RWB2 Monitoring data for Keys Creek (Marin County) to determine beneficial use support and results are as follows: 0 of 1 samples exceeded the water quality threshold for Temperature. | ||||
| Data Reference: | Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2. | ||||
| SWAMP Data: | SWAMP | ||||
| Water Quality Objective/Criterion: | Temperature objectives for surface waters are specified in the San Francisco Bay Regional Water Quality Control Plan. The following temperature objectives apply to surface waters: The natural receiving water temperature of inland surface waters shall not be altered unless it can be demonstrated to the satisfaction of the Regional Board that such alteration in temperature does not adversely affect beneficial uses. The temperature of any cold or warm freshwater habitat shall not be increased by more than 5 degrees F (2.8 degrees C) above natural receiving water temperature. | ||||
| Objective/Criterion Reference: | Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2) | ||||
| Evaluation Guideline: | Scientific literature reviewed by the Washington Department of Ecology and U.S. EPA indicates that stream temperatures higher than 21C are associated with avoidance behavior and migration blockages in steelhead trout. | ||||
| Guideline Reference: | EPA Region 10 Guidance for Pacific Northwest State and Tribal Temperature Water Quality Standards. EPA 910-B-03-002. Region 10 Office of Water, Seattle, WA | ||||
| Guideline Reference: | U.S. Environmental Protection Agency (USEPA). 2001. Issue Paper 1: Salmonid Behavior and Water Temperature Prepared as Part of EPA Region 10 Temperature Water Quality Criteria Guidance Development Project. Region 10, Seattle, WA. EPA-910-D-01-001 May 2001. | ||||
| Guideline Reference: | Washington State Department of Ecology (WDOE). 2002. Evaluating Standards for Protecting Aquatic Life in Washington’s Surface Water Quality Standards: Temperature Criteria. Draft Discussion Paper and Literature Summary. Publication Number 00-10-070. | ||||
| Guideline Reference: | Beschta RL, Bilby RE, Brown GW, Holtby LB, Hofstra TD. 1987. Stream temperature and aquatic habitat: Fisheries and forestry interactions. In: Salo EO, Cundy TW, eds. Streamside management: forestry and fishery interactions. College of Forest Resources, University of Washington, Seattle. Contribution No. 57. Proceedings of a Symposium held at University of Washington, February 12-14, 1986, pp. 191-231. | ||||
| Spatial Representation: | The samples were collected at 1 monitoring site: 201WLK050 (Keys @ Irvin Road). | ||||
| Temporal Representation: | The samples were collected between the dates of 2016-05-27 and 2016-05-27 | ||||
| Environmental Conditions: | |||||
| QAPP Information: | SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.. | ||||
| QAPP Information Reference(s): | This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements. | ||||
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| LOE ID: | 288506 | ||||
| Pollutant: | Temperature, water | ||||
| LOE Subgroup: | Pollutant-Water | ||||
| Matrix: | Water | ||||
| Fraction: | Not Recorded | ||||
| Beneficial Use: | Cold Freshwater Habitat | ||||
| Number of Samples: | 1 | ||||
| Number of Exceedances: | 0 | ||||
| Data and Information Type: | PHYSICAL/CHEMICAL MONITORING | ||||
| Data Used to Assess Water Quality: | Water Board staff assessed SWAMP RWB2 Monitoring data for Keys Creek (Marin County) to determine beneficial use support and results are as follows: 0 of 1 samples exceeded the water quality threshold for Temperature. | ||||
| Data Reference: | Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2. | ||||
| SWAMP Data: | SWAMP | ||||
| Water Quality Objective/Criterion: | Temperature objectives for surface waters are specified in the San Francisco Bay Regional Water Quality Control Plan. The following temperature objectives apply to surface waters: “- The natural receiving water temperature of inland surface waters shall not be altered unless it can be demonstrated to the satisfaction of the Regional Board that such alteration in temperature does not adversely affect beneficial uses. - The temperature of any cold or warm freshwater habitat shall not be increased by more than 5°F (2.8°C) above natural receiving water temperature.” | ||||
| Objective/Criterion Reference: | Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2) | ||||
| Evaluation Guideline: | Per Effects of Temperature, Dissolved Oxygen/Total Dissolved Gas, Ammonia, and pH on Salmonids (Carter 2008, Moyle 1976, and USEPA 1977), the lethal temperature evaluation guideline for both the steelhead adult migration and holding and the steelhead juvenile growth and rearing life stages is 24°C. | ||||
| Guideline Reference: | Temperature criteria for freshwater fish: protocol and procedures. Ecological Research Series. EPA-600/3-77-061 (NTIS PB270032). Prepared by W.A. Brungs and B.R. Jones. U.S. Environmental Protection Agency, Washington, D.C | ||||
| Guideline Reference: | Inland Fishes of California | ||||
| Guideline Reference: | Effects of Temperature, Dissolved Oxygen/Total Dissolved Gas, Ammonia, and pH on Salmonids. Implications for California's North Coast TMDLs. California Regional Water Quality Control Board, North Coast Region | ||||
| Spatial Representation: | The samples were collected at 1 monitoring site: 201WLK050 (Keys @ Irvin Road). | ||||
| Temporal Representation: | The samples were collected between the dates of 2016-05-27 and 2016-05-27 | ||||
| Environmental Conditions: | |||||
| QAPP Information: | SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.. | ||||
| QAPP Information Reference(s): | This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements. | ||||
DECISION ID |
148999 |
Region 2 |
Keys Creek (Marin County) |
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| Pollutant: | Indicator Bacteria |
| Final Listing Decision: | List on 303(d) list (being addressed by USEPA approved TMDL) |
| Last Listing Cycle's Final Listing Decision: | New Decision |
| Revision Status | Revised |
| Sources: | See TMDL documentation |
| TMDL Name: | Tomales Bay Pathogens |
| TMDL Project Code: | 10 |
| Date TMDL Approved by USEPA: | 02/08/2007 |
| Impairment from Pollutant or Pollution: | Pollutant |
| Regional Board Conclusion: | This pollutant is being considered for placement on the CWA section 303(d) List under section 3.11 of the Listing Policy. Under this section when all other listing factors do not result in the listing of a water segment but information indicates non-attainment of standards, a water segment shall be evaluated to determine whether the weight of evidence demonstrates that water quality standard is not attained. If the weight of evidence indicates non-attainment, the water segment shall be placed on the CWA section 303(d) List. When making a listing decision based on the situation-specific weight of evidence, the Regional Water Board must justify its recommendation by: • Providing any data or information including current conditions supporting the decision; • Describing in fact sheets how the data or information affords a substantial basis in fact from which the decision can be reasonably inferred; • Demonstrating that the weight of evidence of the data and information indicate that the water quality standard is not attained; and • Demonstrating that the approach used is scientifically defensible and reproducible. Keys Creek drains to Walker Creek the main tributary to Tomales Bay. The Tomales Bay and its tributaries, including Keys Creek, are impaired by indicator bacteria (pathogens) and subject to the Tomales Bay Pathogen TMDL. The weight of evidence indicates that there is sufficient justification for placing this water segment-pollutant combination on the CWA section 303(d) List, specifically on the being addressed portion of the CWA section 303(d) List because a TMDL has been completed and approved by RWQCB and USEPA, and is expected to result in attainment of the standard. This conclusion is based on the staff findings that: 1. The data used satisfies the data quality requirements of section 6.1.4 of the Policy. Fecal coliform densities measured at several Tomales Bay watershed locations including Keys Creek during the development of the Tomales Bay Pathogen TMDL significantly exceeded the designated water quality objective for shellfish harvesting waters and the water quality objective for contact and non-contact water recreation beneficial uses throughout the watershed. Rural and livestock sources in the Bay watershed were identified as the main cause of high fecal coliform densities in the Bay. The highest fecal coliform densities and/or loadings were observed in the Walker Creek watershed. 2. The TMDL implementation plan states that the overall intent of this implementation plan is to restore and protect beneficial uses of the Bay and its major tributaries by reducing pathogen loadings. The Tomales Bay Watershed sources include: on-site sewage disposal systems, small wastewater treatment facilities and sewage holding ponds, boat discharges, grazing lands, dairies, equestrian facilities, and municipal runoff. The TMDL implementation actions (e.g., the Waste Discharge Requirements from Grazing Operations and the NPDES general stormwater permit), were written to include the entire watershed. As such, the Tomales Bay Pathogen TMDL already applies to the Keys Creek subwatershed. Sources of pathogens exist in the Keys Creek subwatershed and contribute to exceedances of the objectives for water contact recreation. Current conditions indicate that water quality in the Creek is impaired. 3. Fecal coliform densities measured in Keys Creek during the TMDL development were often in excess of 4000 MPN/100 mL. The water quality data are insufficient to determine that water quality have been improved and water quality objectives are met in the Tomales Bay watershed in general and in Keys Creek subwatershed in particular. Therefore, based on the readily available data and information, the weight of evidence indicates that there is sufficient justification for placing this water segment-pollutant combination on the being addressed portion of the CWA section 303(d) List because a TMDL has been completed and approved by RWQCB and USEPA, and is expected to result in attainment of the standard. 4. This process is scientifically defensible and reproducible. The Keys Creek subwatershed was included in the Tomales Bay Pathogen TMDL assessment and determined to be a source of pathogens in the Bay watershed. The TMDL assessment included a rigorous technical review, the public participation process, and approval by U.S. EPA. Additionally, the data analysis for the TMDL made use of the bacteria objectives that were in place at the time of TMDL development. Although these objectives have been subsequently updated, exceedances of the older objectives would also constitute exceedances of the revised (lower) objectives. |
| Regional Board Decision Recommendation: | After review of the available data and information, RWQCB staff concludes that the water body-pollutant combination should be placed on the section 303(d) list because applicable water quality standards are exceeded and a pollutant contributes to or causes the problem. |
| State Board Review of Regional Board Conclusion and Recommendation: | Therefore, based on the readily available data and information, the weight of evidence indicates that there is sufficient justification for placing this water segment-pollutant combination on the being addressed portion of the CWA section 303(d) List because a TMDL has been completed and approved by RWQCB and USEPA, and is expected to result in attainment of the standard. 4. This process is scientifically defensible and reproducible. The Keys Creek subwatershed was included in the Tomales Bay Pathogen TMDL assessment and determined to be a source of pathogens in the Bay watershed. The TMDL assessment included a rigorous technical review, the public participation process, and approval by U.S. EPA. Additionally, the data analysis for the TMDL made use of the bacteria objectives that were in place at the time of TMDL development. Although these objectives have been subsequently updated, exceedances of the older objectives would also constitute exceedances of the revised (lower) objectives. |
| State Board Decision Recommendation: | After review of the available data and information, SWRCB staff concludes that the water body-pollutant combination should not be placed on the section 303(d) list because it cannot be determined if applicable water quality standards are not being exceeded. |
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| LOE ID: | 300325 | ||||
| Pollutant: | Fecal Coliform | ||||
| LOE Subgroup: | Pollutant-Water | ||||
| Matrix: | Water | ||||
| Fraction: | 90th percentile | ||||
| Beneficial Use: | Non-Contact Recreation | ||||
| Number of Samples: | 22 | ||||
| Number of Exceedances: | 0 | ||||
| Data and Information Type: | PATHOGEN MONITORING | ||||
| Data Used to Assess Water Quality: | Water Board staff assessed RWB2 Tomales Bay Bacteria TMDL Monitoring data for Keys Creek (Marin County) to determine beneficial use support and the results are as follows: 0 of the 22 samples exceeded the water quality threshold for Coliform, Fecal. The water quality threshold is based on a 30-day 90% percentile. | ||||
| Data Reference: | WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2. | ||||
| SWAMP Data: | SWAMP | ||||
| Water Quality Objective/Criterion: | Water Quality Control Plan, San Francisco Bay Basin, Chapter III Water Quality Objectives, Section 3.3.1 Bacteria: Table 3-1 provides a summary of the bacterial water quality objectives and identifies the sources of those objectives. The fecal coliform objective for non-contact recreation is a 30-day 90th percentile less than 4000 MPN/100 ML. | ||||
| Objective/Criterion Reference: | Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2) | ||||
| Evaluation Guideline: | |||||
| Guideline Reference: | |||||
| Spatial Representation: | The samples were collected at 1 monitoring site(s), station(s): 201WLK030 (Upper Keys Creek North of Bay Rd. and hwy 1 cross. - 201WLK030). | ||||
| Temporal Representation: | The samples were collected between the days of 2011-03-01 and 2013-07-30 . | ||||
| Environmental Conditions: | |||||
| QAPP Information: | SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.. | ||||
| QAPP Information Reference(s): | This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements. | ||||
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| LOE ID: | 299900 | ||||
| Pollutant: | Fecal Coliform | ||||
| LOE Subgroup: | Pollutant-Water | ||||
| Matrix: | Water | ||||
| Fraction: | Mean | ||||
| Beneficial Use: | Non-Contact Recreation | ||||
| Number of Samples: | 6 | ||||
| Number of Exceedances: | 0 | ||||
| Data and Information Type: | PATHOGEN MONITORING | ||||
| Data Used to Assess Water Quality: | Water Board staff assessed RWB2 Tomales Bay Bacteria TMDL Monitoring data for Keys Creek (Marin County) to determine beneficial use support and the results are as follows: 0 of the 6 samples exceeded the 30-day mean water quality threshold for Coliform, Fecal. | ||||
| Data Reference: | WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2. | ||||
| SWAMP Data: | SWAMP | ||||
| Water Quality Objective/Criterion: | Water Quality Control Plan, San Francisco Bay Basin, Chapter III Water Quality Objectives, Section 3.3.1 Bacteria: Table 3-1 provides a summary of the bacterial water quality objectives and identifies the sources of those objectives. The fecal coliform objective for non-contact recreation is a 30-day mean less than 2000 MPN/100 ML. | ||||
| Objective/Criterion Reference: | Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2) | ||||
| Evaluation Guideline: | |||||
| Guideline Reference: | |||||
| Spatial Representation: | The samples were collected at 1 monitoring site(s), station(s): 201WLK030 (Upper Keys Creek North of Bay Rd. and hwy 1 cross. - 201WLK030). | ||||
| Temporal Representation: | The samples were collected between the days of 2011-03-01 and 2013-07-30 . | ||||
| Environmental Conditions: | |||||
| QAPP Information: | SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.. | ||||
| QAPP Information Reference(s): | This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements. | ||||