Primary Quality Assurance Organization Structure in Region 9

1. Primary Quality Assurance Organization Structure in Region 9 EPA Region 9 Meredith Kurpius August 19, 2010

2. Status of Tribal Air Monitoring • Value of tribal monitoring • Used to protect public health on tribal land • Fills in gaps in ambient air monitoring • Can be for informational purposes (e.g., smoke alerts) or regulatory purposes (NAAQS decisions) • Sometimes there is a question if Tribal data is of sufficient quality for NAAQS decisions, based on limited information about audits and QC checks that may be missed by Tribes, due to funding limits or misunderstandings of the requirements.

3. What is a PQAO? • PQAO: Primary Quality Assurance Organization • “A monitoring organization or a coordinated aggregation of such organizations that is responsible for a set of stations that monitors the same pollutant(s) and for which data quality assessments can logically be pooled.” • Developed as part of monitoring regulations in 2006 • 40 CFR 58 Appendix A (Quality Assurance section)

4. PQAO 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: (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.

5. Current PQAOs in Region 9 • R9 approves PQAO structure • No tribes are currently part of a PQAO • Current PQAOs • Washoe County Health District • Nevada Division of Environmental Protection • Clark County Department of Air Quality and Environmental Management • San Diego County Air Pollution Control District • South Coast Air Quality Management District • California Air Resources Board • Bay Area Air Quality Management District • Hawaii Department of Health • Arizona Department of Environmental Quality • Pima County Department of Environmental Quality • Maricopa County Air Quality Department • Note: Being part of a PQAO is a requirement to collect data for regulatory purposes

6. Summary of QA Requirements • PQAO with Independent Quality Assurance • Approved Quality Planning Documents (QMP, QAPPs, & SOPs) • Approved Network Design Plan • Monitoring sites that are unobstructed and meet siting requirements • Approved FRM/FEM instruments • Meet 75% completeness • Calibrate all equipment and standards (quarterly to annually) • Quality control checks (daily to monthly) • Perform audits (quarterly to semi-annually) • Co-location • PEP/NPAP audits • Technical System Audits • Data reported to AQS quarterly • Data certified annually • QA goals for bias and precision met

7. QA Barriers for Tribes • Many air monitoring regulations apply to the PQAO • Independent standards and audits • Co-located monitoring • EPA’s performance monitoring programs NPAP & PEP • Personnel that are independent from the site operator to conduct independent reviews of the data • Quality Management Documents: QAPPs, SOPs, QMPs • For small organizations this means that a significant percentage of monitoring funds are allocated to meeting these requirements

8. Example: of NPAP/PEP cost savings with Federal implementation • NPAP- $2200/audit • 20% of sites in PQAO audited • Would need 8 sites for 2 audits a year. • PEP- $2000/audit • 5 audits for PQAO with < 5 sites = 10K/year • 8 audits for PQAO with >5 sites = 16K/year Total Savings: $34,400

9. PQAO Options for Tribes • Join a pre-existing state/local PQAO • Create a multi-tribe PQAO • Create a tribe-state/local PQAO • Create a single-tribe PQAO • Remain outside the PQAO structure – only and option for non-regulatory data.

10. Benefits to Being Part of a PQAO • QA requirements can be effectively reduced if multiple organizations work as one PQAO • Cost savings: reduced audits and co-location • Opportunities for cooperation • Data consistency • Opportunities to share expertise • Standardizes formal documentation • Greater consistency • Reduced workload in creation and review of QA documents • Formalizes what Tribes may already be doing

11. Process to Join a PQAO • Request membership from the PQAO lead organization • Choose pollutants • Outline funding mechanism to access EPA audits • Assess common factors with existing PQAO • Establish how requirements for QA documentation will be met • Prepare Memorandum of Agreement (MOA) • Request approval from EPA Region 9 for addition/confirmation of new member to PQAO

12. Reasons to Create New PQAO • An organization is not part of a PQAO and there is no pre-existing PQAO that share common factors. • Note that a PQAO must be able to meet ALL QA requirements • PEP/NPAP audits • technical system audits • Co-location • Precision/accuracy, etc.

13. Process to Form a New PQAO • Identify the PQAO lead organization • Choose pollutants • Arrange and outline funding mechanism to access EPA audits • Document how PQAO requirements will be met • Prepare a Memorandum of Agreement, if there are multiple organizations forming the new PQAO • Request approval from EPA Region 9 to form new PQAO

14. Consequences of not Forming PQAOs • Tribes will continue to spend disproportionate resources to meet QA requirements • Tribes may have trouble meeting QA/QC requirements • The amount of funding needed to perform NPAP and PEP audits may prevent Tribes from collecting data for NAAQS comparison. • EPA may not be able to meet the required TSA frequencies. • Tribes will have to defend independently collected data when Tribal decisions/data are contested • Data may not be used for regulatory decisions!!!

15. Current Status • Region 9 is finalizing the PQAO Strategy Document • Tribes will be able to join/form PQAOs following the PQAO Strategy • EPA Region 9 will work with all tribes collecting air monitoring data to determine the most sensible PQAO structure • PQAO status will be reflected in future grant agreements

16. Contact Information • Meredith Kurpius • Kurpius.meredith@epa.gov • 415-947-4534