QA101- Plus Air Session 1: QA Systems, EPA Definitions, PQAOs and Common Sense

1. QA101- Plus AirSession 1: QA Systems, EPA Definitions, PQAOs and Common Sense Institute for Tribal Environmental Professionals, Tribal Air Monitoring Support Center Guest Speaker: Mike Papp, OAQPS

2. Overall Course Overview: • April 7: QA Systems, EPA definitions, PQAOs and common sense – Mike Papp • April 14: Routine Quality Control and Data Management (1-pt QC, flow rate, and instrument stability checks) • April 21: Audits Overview (NPAP, PEP, Annual PE, Flow Rate Audits) – Jeremy Howe • April 28: Calculating Bias and Precision and AQS reports • May 5: 40 CFR 58 App. A- Gaseous Pollutants – Glenn Gehring • May 12: 40 CFR 58 App. A- Ozone – Brenda Jarrell • May 19: 40 CFR 58 App. A- PM filter and continuous methods –Brandy Toft

3. Overview of session 1: • Why QA? • Quality systems • Terminology • QMPs, QAPPs, and other monkeys • EPA’s Graded Approach • CFR online • Appendix A intro • PQAOs

4. Donora PA 1948 London Killer Fog

5. { “(2) Establishment of a national network to monitor, collect, and compile data with quantification of uncertainty in the status and trends of air emissions, deposition, air quality, surface water quality, forest condition, and visibility impairment and to ensure the comparability of air quality data collected in different States and obtained from different nations.”

6. Quality Assurance E4- Part of quality management focused of providing confidence that quality requirements will be fulfilled. Another Definition- A system of activities whose purpose is to ensure that information derived from measurements are of a quality that the decision maker is willing to risk making an inappropriate decision. Premise 1 - All estimates have error so all decisions made with estimates have risks. Premise 2 - We can’t afford 100% certainty in our decisions

7. Some decisions will be inappropriate (wrong) due to data uncertainty…(error) …the difference between your measurement (estimate) and the “truth”

8. Why QA? • The purpose of QA is to help you get the data you need to answer the questions you have as cheaply and quickly as possible • It can quantify uncertainty and comparability • QA done right does save you time and money • QA makes you: • Plan ahead • Ensure everyone agrees to the: • goals and equipment used, • what their jobs are, • the schedule, and • who reports what to whom when

9. EPA follows: American National Standard ANSI/ASQC E4-2004 Quality Systems for Environmental Data and Technology Program • National consensus standard authorized by American National Standards Institute (ANSI) • Developed by American Society for Quality (ASQ) • Consistent with ISO standards (there are ISO standards for everything, drill bits, toilets, diapers, tires) • EPA adds to E4 with: • EPA Quality Policy 2106.0 and Procedure for Quality Policy 2106-P-1.0 • EPA Guidance for Quality Management Plans: EPA QA/G-2 • EPA Guidance for Quality Assurance Project Plans: EPA QA/G-5 EPA Quality Staff Web site http://www.epa.gov/quality1

10. What is a Quality System? A blue print of how an organization produces quality products.

11. develops and implements the quality policy defined in a monitoring organization's QMP. • includes strategic planning, allocation of resources and other systematic planning activities (e.g., planning, implementation, assessing and reporting) pertaining to the quality system. • must have sufficient technical expertise and management authority to conduct independent oversight and assure the implementation of the organization's quality system relative to the ambient air quality monitoring • should be organizationally independent of environmental data generation activities.

12. Program that makes sure the quality requirements are fulfilled • Activities that provide checks on specific areas of a process to help keep them acceptable Example of QA/QC in daily life : Personnel Finances • Quality System: have enough money to pay the bills and plan for a fun retirement • QA are the activities of: • Setting up a long range goal • Establishing monthly budget • Allocating $$ for checking and saving • Reviewing IRA statement monthly, determine reallocation annually • Depositing checks • QC is: • routinely balancing our checkbooks and calculating whether checks written or online payments are going to bounce • Checking bill statement for errors

13. Quality System Parts: QMPs, QAPPS and SOPs • QMP • Describes orgs quality system • Establishes capability • QA Project Plan • Identifies the reasons for collecting data and for collecting it in a specific way • Documents how the data are collected and how quality is maintained • SOP • Ensures consistency • From day to day • From one person to the next • Ford • Mustang • engine Quality is Job 1

14. QMPs vs. QAPPs • Quality Management Plans reflect activities and policies common to all projects. • Quality Assurance Project Plans reflect specific projects. QMP QAPP QAPP QAPP QAPP

15. The Quality Management Plan must discuss: • Mission and quality policy of the organization • Specific roles and responsibilities with respect to QA and QC activities • Means and structure to assure effective communication • Processes used to plan, implement , assess and report work and the effectiveness of QA and QC activities • Process for continual improvement of the Quality System

16. The QAPP Must provide sufficient detail to show that: • The project objectives are identified • The intended measurements are appropriate for achieving project objectives • The assessments (audits QC checks, data reviews) are sufficient for confirming that data of the type and quality needed are obtained • Data use limitations are defined (e.g.; non-regulatory monitor type data can’t be used for NAAQS)

17. Why is a QAPP Important? • Saves money • Saves time • Helps communication • No later misunderstandings • Everything contained in or referenced in one document • Public document in case of litigation

18. EPA Uses a Graded Approach QA and QC requirements based on: • Importance of work • Available resources • Unique needs of organization • Consequences of making an wrong decision with the data http://www.epa.gov/ttn/amtic/qaqcrein.html

19. Graded Approach for Air Monitoring Important Decisions • Category 1 projects are to compare against the NAAQS standard, and require all 24 elements • Category 2-3 projects would include looking at air pollution transport, air toxics, exploratory studies, or evaluating whether further measurements should be made, and require even fewer of the 24 elements of a QAPP • Category 4 projects are education and outreach and may make a few qualitative measurements and only require 6 elements of a QAPP (see example on course website) Less Important Decisions

20. Quality Assurance improving your program Quality Control training documentation Within the quality system:

21. Quality Systems for Ambient Air Taking the overall EPA Requirements and bringing them into the Ambient Air Monitoring Program

22. EPA Responsibility Air Quality Monitoring Org Standard Responsibility Ambient Emergency Air Data Trends Control Research Analysis Real Time Reporting (AQI) Attainment of Air Quality Standards Control Strategy State/Tribal Adjust Implementation Classification Plan Continue Air Quality Measurement Monitoring Objectives Criteria Pollutants • Ozone • CO • SO2 • NO2 • Pb • Particulate Matter • PM10 • PM2.5 NAAQS

23. Accessing CFR: • Demo how to download sections at e-CFR • Copies available in course website

24. Regulations Are requirements Must be followed Usually minimum requirements.. more is better Guidance More details on regulations Provides additional suggestions or strongly suggests Are not mandatory, but you need an acceptable alternative EPAQuality Program Policy CIO 2106.0 R-Requirements G-Guidance OAQPS 40 CFR Part 58 Appendix A Redbook Guidance Mon. Orgs QMP, QAPP, SOPs Requirements Vs. Guidance

25. EPA Regs • QA Policy • CFR Contracts and Grants • R2- QMP • R5 – QAPPs • 40 CFR Part 58 App A • Guidance • G2- QMP • G5-QAPP • QA Handbook Vol II • QA Handbook Volume IV • TADs, White Papers, etc

26. Go to AMTIC Home page click on

27. 40 CFR Pt. 58 App. A QA Requirements Section 1 General Info Measurement Uncertainty Measurement Quality Checks Assessment and Reports Section 2 QMPs/QAPPs* Independent quality management function* DQOs- (EPA) PM2.5, O3, PM10-2.5 NPAP/PEP TSAs-(EPA Regions) NIST Traceable Standards Section 3 PQAO definition Quality Control and Assessment 1-point QC Annual PE Flow Rate Verification Flow Rate Audit Collocated Sampling PEP Section 4 QA Stats Section 5- Reporting Req. List- Site ID/PQAO by pollutant Quarterly submission of QA per 58.16 reporting requirements Calculation of QA (EPA) once annual submission occurs * EPA QA Policy (covered earlier) } Gaseous pollutants } PM/Pb There is so much more to QA beyond Appendix A

28. Appendix A Section 1.2 -Measurement Uncertainty • Deviations from the “true” concentration • Defined in terms of data quality indicators: • Bias • Precision • Completeness • Detectability }accuracy Other data quality indicators like comparability and representativeness are important, but since they relate to spatial/temporal variability or data outside the control of a monitoring organization, they are not included in Appendix A.

29. Appendix A Section 1.3 - Measurement Quality Checks Acknowledging that the quality control checks in Section 3 are required to be reported to AQS. One exception- flow rate verifications (with the exception of automated PM10) are not required to be reported to AQS. However, they can be reported if desired.

30. Official Primary Quality Assurance Organization definition: Each primary quality assurance organization shall be defined such that measurement uncertainty among all stations in the organization can be expected to be reasonably homogeneous, as a result of common factors. Common factors that should be considered by monitoring organizations in defining primary quality assurance organizations include, but all are not strictly necessary (see Region 5 and OAQPS PQAO guidance): (a) Operation by a common team of field operators according to a common set of procedures; (b) Use of a common QAPP or standard operating procedures; (c) Common calibration facilities and standards; (d) Oversight by a common quality assurance organization; and (e) Support by a common management, laboratory or headquarters.

31. PQAO Consolidation Benefits • Development of one QAPP and SOPs • Fewer sets of calibration equipment • Independent QA management for consolidated PQAO • Reduced requirements (and resources) for collocation, PEP and NPAP • Data Reporting

32. Successful PQAO Consolidations • The Aroostook Band of Micmac Indians, the Passamaquoddy Tribe and the Penonobscot Nation have sites that are consolidated with the State of Maine. • The Wampanoag Tribe of Gay Head is consolidated with the State of Massachusetts. • The Little River Band of Ottowa has consolidated with the State of Michigan. • The Little Travers Bay Band has consolidated with the Inter-Tribal Council of Michigan • The Fond du Lac Band of Minnesota Chippewa and the Mille Lacs Band of Minnesota Chippewa have consolidated with the State of Minnesota. • The Bad River Band of Lake Superior Tribe of Chippewa Indians and the Forest County Potawatomi Community have consolidated with the State of Wisconsin

33. Process to Join a PQAO • Work with the EPA Regions. Regions that have performed consolidation have some guidance developed. • Assess common factors with monitoring organizations that are consolidating. • Establish how requirements for QA documentation/implementation will be met. • Prepare some agreement documentation and formalize.

34. Conclusions: • Anyone expecting their data to be respected must have some form of quality system (remember this is just good management plus documentation, in a QAPP) • Anyone receiving grant funds from a federal agency must have a quality system • Even 1-person programs can have data that is legally and scientifically defensible by following the guidelines

35. Conclusions: • QA/QC comes down to common sense and documentation • Subsequent webinars will cover pollutant specifics • Course website: http://itep68.itep.nau.edu/itep_downloads/ • Our emails: • Papp.michael@epa.gov • Melinda.ronca-battista@nau.edu • Christopher.lee@nau.edu

36. The big picture: Quality System = good management