Tribal Air Monitoring and QA Requirements for NAAQS- Comparable Data

1. Tribal Air Monitoring and QA Requirements for NAAQS- Comparable Data Melinda Ronca-Battista, ITEP, TAMS Center

2. QA Requirements and Common-Sense AUDITS • Clean Air Act Section 103 • “(2) Establishment of a national network to monitor, collect, an 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.” 2

3. NAAQS Attainment • NAAQS attainment decisions depend on data gathered: • By an organization getting 3 types of audits: • 1st type: Annual performance evaluations with independent equipment • 2nd type: Annual federal NPAP (gaseous) or PEP (PM2.5) audits • 3rd type: EPA regional TSAs every 3 years • By an organization with an “independent QA function” • Tribal PQAO consolidation (for QA data only!) can help meet these objectives AND save tens of thousands of dollars each year

4. Official Primary Quality Assurance Organization (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, 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. 4

5. PQAO Consolidation Benefits • Development of one QAPP and set of SOPs • Fewer sets of calibration equipment • Independent QA management for consolidated PQAO • Reduced requirements (and resources) for collocation, PEP and NPAP • Data Reporting 5

6. Successful PQAP 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 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 6

7. Process to Form a PQAO • Choose pollutants • Outline funding mechanism to have the 3 types of audits • Assess common factors within 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

8. Considerations • Keep in mind that both annual Performance Evaluation Audits and the federal audits (NPAP and PEP) are required for NAAQS data • These audits MUST be done to have data that can be used for NAAQS attainment decisions • Consolidation into PQAOs can share the costs of these audits ($2200-$3000, and one audit per quarter required for PM2.5)

9. Spreadsheet Tool • Mike Papp (OAQPS) and Jeremy Howe (Little River Band of Odawa) created a spreadsheet showing number, types and frequency of audits required for your program: http://itep68.itep.nau.edu/itep_downloads/QA101_Resources • Calculations for Tribes Interested in Joining a Tribal PQAO.xls • FILL IN the spreadsheet and see what audits you need to produce NAAQS-comparable data

10. A gas analyzer’s example, 3 at 1 site:

11. For this tribe, they need 3 annual PEs and 1 NPAP 11

12. Technical Systems Audits • 2.5 : Technical Systems Audits of each ambient air monitoring organization shall be conducted at least every 3 years by EPA regional office • Review of siting, documentation, procedures’ implementation • Assessment of whether the “QA function is independent” • Checklists that the region will use are available as QA Handbook Volume II, Appendix H • OAQPS has policy that if regions do not have personnel to conduct TSAs, data that meets Appendix A requirements and passed audits is still NAAQS-comparable. 12

13. TSAs cont. • At least 3 months notice, with written audit plan • Checklist sent ahead of time, see NAAM Technical Systems Audit Form in: http://itep68.itep.nau.edu/itep_downloads/QA101_Resources/EPA%20guidance%20and%20other%20reference%20material/ 13

14. How are Audit Results Used? • All audits are “friendly” and intended to improve the quality of the data • Findings will always include “insufficient documentation”—use checklists & SOPs! • Site visits are included • Some AQS data are pulled, then records of all the QC and original data are looked for in office • Important for small organizations: the “independency of the QA function” 14

15. “Independent” QA Function • CFR App. A: 2.2  …a quality assurance management function…includes strategic planning, allocation of resources and …assessing and reporting… • must have sufficient technical expertise and management authority to conduct independent oversight… • should be organizationally independent of environmental data generation activities (e.g., NOT the site operator or their manager) • Ideal QA manager is described at: http://www.epa.gov/ttn/amtic/files/ambient/monitorstrat/qamroles2.pdf 15

16. What the TAMS Center Can Do • Auditors (including tribal folks) can take training and exam • Equipment must be approved/provided as audit-specific equipment • SOPs available on AMTIC: http://www.epa.gov/ttn/amtic/npepqa.html • Self-implementation of NPAP is possible: http://www.epa.gov/ttnamti1/files/ambient/pm25/qa/FinalNPAPPEP2011.pdf

17. 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 • Tribes should consider PQAOs as the best option to reduce QA/QC burdens and improve data quality. 17